Last week, the National Labor Relations Board (“Board” or “NLRB”) decided that an employer no longer can unilaterally stop union dues deductions from employee pay pursuant to a dues-checkoff clause once a collective-bargaining agreement (“CBA”) expires absent a lawful impasse during negotiations for a successor agreement. Valley Hosp. Med. Ctr., Inc., 371 NLRB No. 160 (2022) (“Valley Hosp. II”). The decision marks another reversal of Board precedent in favor of unions by the Biden NLRB.