Enforce maintenance of compensation

Years 1–4 (requirement lasts 3 years after each worker's wave) · DOL Wage & Hour Division; employers; unionsDiscuss this step

Every concrete action this step requires, who is responsible, and when it happens relative to enactment.

#	Action	Owner	When	Trade-off
2.3.1	Require employers to report per-worker health premium contributions in the last full year before each worker's wave (from W-2 box 12, code DD).	IRS / DOL	Year 0	Using W-2 premium data is objective but misses benefits not reported on W-2s.
2.3.2	For 3 years after each wave, employers must pay each affected worker at least: prior premium contribution − new employer tax attributable to that worker, as wages, retirement contributions, or other benefits.	Employers	Each wave	Mandated compensation conversion protects workers but constrains employers' pay decisions for 3 years.
2.3.3	Union contracts: savings are added to the bargaining table as wages or pensions; reopener clauses triggered by law.	Unions / employers	Each wave	Reopening union contracts preserves bargaining but invites disputes over how savings are split.
2.3.4	Worker-paid premiums end; paycheck deductions stop, raising take-home pay.	Employers	Each wave	Ending paycheck deductions raises take-home pay but also raises taxable income.
2.3.5	Complaint and audit system with back-pay remedies.	DOL	Year 1+	Back-pay remedies enforce the rule but add litigation and audit costs.