(December 18, 2017, 1:34 PM EST) -- WASHINGTON, D.C. — The National Labor Relations Board, in a 3-2 decision issued Dec. 15, overruled E.I. du Pont de Nemours, 364 NLRB No. 113 (2016) (DuPont), calling the majority opinion “fundamentally flawed” and holding that an employer’s modification of unit employee health care benefits following the expiration of a collective bargaining agreement (CBA) was simply a continuation of past practice and not a “change” requiring notice to the union and an opportunity to bargain (Raytheon Network Centric Systems and United Steel, Paper & Forestry, Rubber, Manufacturing, Energy, Allied Industrial & Service Workers International Union, AFL-CIO, No. 25-CA-092145, NLRB)....