PDF - CUPA-HR
FLSA Overtime: How, When and Why to Prepare Sponsored by
February 16, 2016
Partner Organizations The following organizations have joined us in presenting this webinar.
Partner Organizations The following organizations have joined us in presenting this webinar.
Presenters
Ricardo Coronado, Tarrant County College District
Jennifer Donnelly, Sibson Consulting
Sharon Thomas, George Mason University
John Whelan, Indiana University
Heather Murray, Gonzaga University
Linda Peltier, Edison State Community College
Carolyn Wong, Sibson Consulting
Brief Overview of Proposed FLSA Regulations, Initial Concerns, and Potential Impact on Higher Education Jennifer Donnelly Vice President Carolyn Wong Senior Consultant
4
Introduction The Fair Labor Standards Act (FLSA) is a federal law that governs whether or not employees receive overtime pay. President Obama tasked the Department of Labor (DOL) with updating the FLSA regulations in early 2014. Proposed regulations were released in July 2015 with the primary change of raising the salary threshold that generally determines who is eligible for overtime pay.
5
Proposed FLSA Changes Timeline* Changes proposed to FLSA
July 6
September 4
Potential Release of Final Regulations
Labor department review begins
Fall 2015
Comment period ends
Early 2016
Mid-Late Grace Period 2016
Labor department review ends
TBD
After the DOL publishes the annual increase to the salary threshold, organizations have 60 days to comply before the new threshold becomes effective. * Timeline indicated above is proposed and subject to change.
6
Comparison of Current vs. Proposed Changes CURRENT (Since 2004)
PROPOSED Minimum Salary Threshold
$970/week or $50,440/year*
For exempt status, the employee’s primary duty must still be administrative, executive, professional, or related to outside sales
Job Duties Test
No changes released as of July. However, discussion around potential change to limit amount of time exempt employees could perform non-exempt work
Exempt status at $100,000/year Must partake in office or non-manual work and perform at least one administrative or professional duty
Highly Compensated Workers (HCW) Test
Exempt status set at $122,148 (90th percentile of weekly earnings) No changes proposed in duties required
$455/week or $23,660/year
* Proposed threshold for 2016 set at 40th percentile of earnings for all full-time salaried workers
7
Concerns About Proposed Changes • Salary threshold of $50,440: − Is seen as too high and has significant impact on higher education − Does not account for regional differences and areas with lower cost of living • Definition of salary threshold (40th percentile) does not match historic trends • 60-day implementation period is too short: − May conflict with institution’s budget planning process − Will be challenging for institutions to plan and administer changes, and balance competing priorities strategically • Unique positions in higher education make it challenging to meet the demands of any changes to the FLSA regulations • Effect on part-time exempt employment is unclear 8
Poll Question What portion of your exempt population do you expect will be impacted by the proposed salary threshold? Less than 10% About 25% About 50% More than 50%
9
Potential Impact of Proposed Changes Significant Financial Costs
Large financial impact due to salary increases for exempt employees, new overtime payments, hiring of additional staff, costs associated with layoffs, and benefit reclassifications
Organizational and Cultural Challenges
Changes may affect salary equity, ability to recruit and retain top talent, career paths and development opportunities, succession planning, and employee engagement and morale
Modification of Processes/ Structures/Systems
Modifications of internal processes/structures/systems may be needed to accommodate the significant number of employees moving from exempt to non-exempt status. These may include the job description process, organizational structure, workload distribution, timekeeping procedures, and compensation and benefits policies
Need for Change Management, Communication and Training
Significant change will require timely, tailored communication from Senior Management and HR to ease employee anxiety and stress. Comprehensive training and education for managers and leaders across the institution will be critical to ensure compliance. A focus on change management will be important for successful implementation 10
Specific Functional Area Considerations
Academic Positions
Admissions, Athletics, Development
• Positions that spend a portion of time teaching/ instructing students may be subject to classification changes under the proposed regulations (adjunct faculty, teaching assistants, etc.)
• Positions that require significant travel, irregular hours, or fluctuating seasonal demands will be affected by proposed changes (admissions counselors, athletic coaches, development officers, etc.)
• Research professional salaries, particularly those funded by grants, are typically below the proposed minimum threshold level
• Institutions will need to accurately track and capture all work hours for these positions, while balancing and controlling for overtime costs
• Research professionals have flexibility and autonomy in conducting their research. Reclassification and/or compensation restrictions will likely change how they conduct their work and lead to a loss of flexibility, productivity, innovation, teaching, and discovery
• Institutions may need to consider changes to their academic strategy, overall faculty structure, and faculty workload/course load as a result of the regulations
Research
• Institutions may see a decrease in research positions and/or grant funding as limited funds are used to increase employee salaries above threshold level
11
Considerations and Preparation for Upcoming Changes What can you do now? • Identify employees that earn salaries in the $23,660 to $50,440 range and conduct an analysis of: − − − −
Costs to bring employees to minimum salary threshold Overtime hours actually being worked Wage compression issues Benefit cost changes
• Review organizational structure and work with functional leaders to discuss how to modify and manage structure, jobs, staffing levels, and career advancement/growth opportunities given changes • Examine current compensation structure to determine effect of reclassification of employees • Review relevant policies (e.g. compensation and benefits, timekeeping, classification process, etc.) and make revisions where needed • Begin to develop training strategies to ensure compliance • Assess time and attendance processes, work flows and systems and develop plans to revise processes to support effective roll-out and administration of changes • Assess and monitor climate and engagement of employee population
12
Poll Question Which of the potential areas of impact is the greatest concern for your institution? Financial Cost Cultural Challenges Processes/Systems Change Management
13
Preparing To Do the Work Sharon Thomas Workforce Planning Manager
14
George Mason’s Cost Estimates George Mason University is a public university in Fairfax VA; top Carnegie research ranking; 34,000 students; 4,000 full time faculty & staff Estimated Annual Costs (excluding fringe) Increase salary to $50,440 to remain exempt Exempt Employee Type Post Docs $ 90,036 Research Faculty $ 419,016 Administrative Faculty $ 135,306 Professional Faculty $ 1,038,887 Staff ($45,855 & above) $ 422,067 Staff ($45,854 & below) N/A Total $ 2,105,312
No salary increase, change to nonexempt & overtime estimates 1 hour overtime 5 hours overtime per week per week $ 32,230 $ 161,151 $ 106,255 $ 531,277 $ 57,290 $ 286,452 $ 143,849 $ 719,245 $ 241,323 $ 1,206,618 $ 111,265 $ 556,322 $ 692,212 $ 3,461,065
15
George Mason’s Concerns • Post Docs & Research Faculty – Postdoctoral fellowships – Nature of research work – Grant funding • Coaches – Scheduling differences when sport is in/out of season – Self-generated funding • Support Staff – State limitations – Compression – Uncertain overtime
16
Strategy Heather Murray Associate Director of Human Resources
17
FLSA = UFO Gonzaga University is a private, Jesuit institution, non-research and nonunion with slightly over 1,400 faculty and staff • GU-HR’s approach
– UFO = Un-Funded Obligation
• Scope of evaluation:
– Efficiencies—where can we best utilize technology services and recognize changing nature of work – Consider additional headcount or something must give – Consider salary increase to threshold to remain exempt classification— with a formal position re-evaluation and only if cost is manageable – Change position’s classification to non-exempt and incur the potential OT
18
Impact Analysis
• Do not lose sight of intent of the law • Long-term impact—inflating market data • Find balance between work expectations and quality of life • OT is a controllable expense • Set policy on what constitutes reasonable OT
19
Strategies • Leadership position = no adjusting description or competencies without a formal evaluation to FLSA criteria and benchmark against survey data • Committed to appropriate OT funding—HR partnering with Finance to create a centralized contingency – Formula = 2x of last year’s OT spend – Intent is to manage the $$$ and maintain culture alignment based on University’s mission
• Policy revision—actively discussing potential policy implications – Vacation accrual rates – Travel policy
20
Strategies continued Educate, Educate, Educate • Create a holistic education effort • Develop training for supervisors and individual contributors across all areas on campus • Hold open meetings • Present at departmental meetings • Establish tone of shared responsibility
21
Poll Question Does your college or university have different benefits or perks for exempt and non-exempt employees? Yes No
22
Morale John Whelan Associate Vice President and Chief HR Officer
23
Morale Indiana University is a public research university with 114,000 students and 23,000 faculty and staff members on eight campuses • Identify changes to impacted employees
– Pay, work schedule, benefits, perceived status, career concerns, certifications, etc.
• Assess emotional reactions or impact to morale – What are the most sensitive issues?
• Communicate
– Lead rather than react – Explain facts and rationale, but empathize – Caution—audience is more than just impacted employees – Role for more than just compensation person(s)
• Avoid unnecessary complications
– If possible, decisions should not be strictly financial
24
Poll Question In which area of your institution do you anticipate the biggest impact to occur? Student Affairs/Services Administrative Athletics Admissions Other
25
Community College Challenges Linda Peltier Executive Director of Human Resources
26
Addressing the challenges of the new OT regulations Edison State Community College is a two-year public institution with 143 faculty and staff serving 2,700 students • Are your job descriptions up-to-date to include current exempt or non-exempt status? – In 2009 Edison implemented a new grade/salary structure which has enabled us to keep our job descriptions up-to-date
• Which positions are going to be impacted?
– At Edison, the areas impacted the most are the coordinators/directors of: • Financial Aid • Athletics/Student Life • Marketing • Student Affairs/ • Library • Human Resources Admissions • IT
• What about the budget and preparing for our July 1st fiscal year? – The lowest annual salary of employees impacted in this group is $34,657 – The new regulations will impact 26 of our 47 professional/technical employees, elevating our non-exempt number from 31 to 57 – No, our budget cannot accommodate increasing their annual salaries to meet the new threshold!
27
How To Prepare Establishing a plan • In assessing the positions, some will only be impacted during high enrollment times and at the start of each semester. We will control some of this through flex time. Other positions like our Director of Financial Aid, Director of Athletics/Student Life, and IT positions will have more of a budget impact due to the necessity of working overtime – Tracking OT hours will be foreign and cumbersome for these employees – Supervisors will need to estimate the projected OT hours/costs to be presented during their budget planning process
• Taking into consideration the total compensation package, it is not an option for our budget to add positions. It is more feasible to pay the overtime. The challenge will be to assure that it is applied consistently across campus • Strengthen our policies and procedures to make sure that employees know the specific guidelines for working overtime. One of the primary focuses will be on reading and responding to e-mails after hours and on weekends • Change is not easy, therefore, communication and training is going to be essential with accountability being an important piece 28
Community College Challenges continued Ricardo Coronado Associate Vice Chancellor for Human Resources
29
FLSA Salary Exemption Pay Level Tarrant County College is a comprehensive two year institution with over 50,000 students across six major campuses • Current Salary Range Level for Exempt Employees
– Lowest Class Code (Pay Grade 15) for Professional Staff including part-time – Lowest Class Code for 12- month Continuing Education Instructors – Exempt Pay Starts at $46,792
• New Proposed Min. Salary for Exempt Employees – New Min. Exempt Pay will increase to $50,440
30
FLSA & Pay Implications • Budget implications for salary and fringe benefits. Estimated Cost: $305,552, not including new hires coming in (Class Code 15 - 96 FT and 45 PT) • May cause salary compression and pay equity issues with the class code (pay grade and salary ranges) above it. Estimated Cost: $126,665 – 36 FT and 10 PT • This will impact a small number of our full-time 12-month Continuing Education Instructors. Their pay is significantly lower than the new threshold of $50,440. Estimated Cost $176,655 – 20 FT and no part-time impacted • Tarrant County College is fortunate to have positioned itself to have a higher annual salary for all of its salaried, exempt employees than most of the other community colleges. We are in a highly competitive market, able to pay, and have maintained a good market position. Total Estimated Cost: $608,872 31
Compliance John Whelan Associate Vice President and Chief HR Officer
32
Compliance—Issues • We already do this, what’s the big deal? • FLSA classification normally determined before employees are hired into role
– Supervisors and employees understand expectations and work parameters (mostly…)
• Switching existing employees from exempt to non-exempt may mean big changes – Work schedule, 9-5, cell phone, emails, tracking hours, etc. – Need to do more with less – Technology makes this a greater challenge
• May be perceived “Lose – Lose” by supervisor and employee – Temptation to ignore
33
Compliance—HR Role • Educate supervisors and employees
– Start with basics – how OT works, tracking time, comp time, etc. – Employee can’t opt out of OT pay (we know this, but now it may be tested more than ever) – Impact to the institution if not compliant
• HR has opportunity to be “strategic partner” – Workforce planning – Coaching – OD
• Plan to do audit and course correct if necessary (before DOL decides to!)
34
Poll Question How likely are you to take action to prepare for the proposed FLSA regulation changes in the next 4 – 6 weeks? Unlikely Somewhat Likely Likely Very Likely Definitely 35
Questions/Answers
36
FLSA Overtime: How, When and Why to Prepare
Thank you! Sponsored by
February 16, 2016
February 16, 2016
Partner Organizations The following organizations have joined us in presenting this webinar.
Partner Organizations The following organizations have joined us in presenting this webinar.
Presenters
Ricardo Coronado, Tarrant County College District
Jennifer Donnelly, Sibson Consulting
Sharon Thomas, George Mason University
John Whelan, Indiana University
Heather Murray, Gonzaga University
Linda Peltier, Edison State Community College
Carolyn Wong, Sibson Consulting
Brief Overview of Proposed FLSA Regulations, Initial Concerns, and Potential Impact on Higher Education Jennifer Donnelly Vice President Carolyn Wong Senior Consultant
4
Introduction The Fair Labor Standards Act (FLSA) is a federal law that governs whether or not employees receive overtime pay. President Obama tasked the Department of Labor (DOL) with updating the FLSA regulations in early 2014. Proposed regulations were released in July 2015 with the primary change of raising the salary threshold that generally determines who is eligible for overtime pay.
5
Proposed FLSA Changes Timeline* Changes proposed to FLSA
July 6
September 4
Potential Release of Final Regulations
Labor department review begins
Fall 2015
Comment period ends
Early 2016
Mid-Late Grace Period 2016
Labor department review ends
TBD
After the DOL publishes the annual increase to the salary threshold, organizations have 60 days to comply before the new threshold becomes effective. * Timeline indicated above is proposed and subject to change.
6
Comparison of Current vs. Proposed Changes CURRENT (Since 2004)
PROPOSED Minimum Salary Threshold
$970/week or $50,440/year*
For exempt status, the employee’s primary duty must still be administrative, executive, professional, or related to outside sales
Job Duties Test
No changes released as of July. However, discussion around potential change to limit amount of time exempt employees could perform non-exempt work
Exempt status at $100,000/year Must partake in office or non-manual work and perform at least one administrative or professional duty
Highly Compensated Workers (HCW) Test
Exempt status set at $122,148 (90th percentile of weekly earnings) No changes proposed in duties required
$455/week or $23,660/year
* Proposed threshold for 2016 set at 40th percentile of earnings for all full-time salaried workers
7
Concerns About Proposed Changes • Salary threshold of $50,440: − Is seen as too high and has significant impact on higher education − Does not account for regional differences and areas with lower cost of living • Definition of salary threshold (40th percentile) does not match historic trends • 60-day implementation period is too short: − May conflict with institution’s budget planning process − Will be challenging for institutions to plan and administer changes, and balance competing priorities strategically • Unique positions in higher education make it challenging to meet the demands of any changes to the FLSA regulations • Effect on part-time exempt employment is unclear 8
Poll Question What portion of your exempt population do you expect will be impacted by the proposed salary threshold? Less than 10% About 25% About 50% More than 50%
9
Potential Impact of Proposed Changes Significant Financial Costs
Large financial impact due to salary increases for exempt employees, new overtime payments, hiring of additional staff, costs associated with layoffs, and benefit reclassifications
Organizational and Cultural Challenges
Changes may affect salary equity, ability to recruit and retain top talent, career paths and development opportunities, succession planning, and employee engagement and morale
Modification of Processes/ Structures/Systems
Modifications of internal processes/structures/systems may be needed to accommodate the significant number of employees moving from exempt to non-exempt status. These may include the job description process, organizational structure, workload distribution, timekeeping procedures, and compensation and benefits policies
Need for Change Management, Communication and Training
Significant change will require timely, tailored communication from Senior Management and HR to ease employee anxiety and stress. Comprehensive training and education for managers and leaders across the institution will be critical to ensure compliance. A focus on change management will be important for successful implementation 10
Specific Functional Area Considerations
Academic Positions
Admissions, Athletics, Development
• Positions that spend a portion of time teaching/ instructing students may be subject to classification changes under the proposed regulations (adjunct faculty, teaching assistants, etc.)
• Positions that require significant travel, irregular hours, or fluctuating seasonal demands will be affected by proposed changes (admissions counselors, athletic coaches, development officers, etc.)
• Research professional salaries, particularly those funded by grants, are typically below the proposed minimum threshold level
• Institutions will need to accurately track and capture all work hours for these positions, while balancing and controlling for overtime costs
• Research professionals have flexibility and autonomy in conducting their research. Reclassification and/or compensation restrictions will likely change how they conduct their work and lead to a loss of flexibility, productivity, innovation, teaching, and discovery
• Institutions may need to consider changes to their academic strategy, overall faculty structure, and faculty workload/course load as a result of the regulations
Research
• Institutions may see a decrease in research positions and/or grant funding as limited funds are used to increase employee salaries above threshold level
11
Considerations and Preparation for Upcoming Changes What can you do now? • Identify employees that earn salaries in the $23,660 to $50,440 range and conduct an analysis of: − − − −
Costs to bring employees to minimum salary threshold Overtime hours actually being worked Wage compression issues Benefit cost changes
• Review organizational structure and work with functional leaders to discuss how to modify and manage structure, jobs, staffing levels, and career advancement/growth opportunities given changes • Examine current compensation structure to determine effect of reclassification of employees • Review relevant policies (e.g. compensation and benefits, timekeeping, classification process, etc.) and make revisions where needed • Begin to develop training strategies to ensure compliance • Assess time and attendance processes, work flows and systems and develop plans to revise processes to support effective roll-out and administration of changes • Assess and monitor climate and engagement of employee population
12
Poll Question Which of the potential areas of impact is the greatest concern for your institution? Financial Cost Cultural Challenges Processes/Systems Change Management
13
Preparing To Do the Work Sharon Thomas Workforce Planning Manager
14
George Mason’s Cost Estimates George Mason University is a public university in Fairfax VA; top Carnegie research ranking; 34,000 students; 4,000 full time faculty & staff Estimated Annual Costs (excluding fringe) Increase salary to $50,440 to remain exempt Exempt Employee Type Post Docs $ 90,036 Research Faculty $ 419,016 Administrative Faculty $ 135,306 Professional Faculty $ 1,038,887 Staff ($45,855 & above) $ 422,067 Staff ($45,854 & below) N/A Total $ 2,105,312
No salary increase, change to nonexempt & overtime estimates 1 hour overtime 5 hours overtime per week per week $ 32,230 $ 161,151 $ 106,255 $ 531,277 $ 57,290 $ 286,452 $ 143,849 $ 719,245 $ 241,323 $ 1,206,618 $ 111,265 $ 556,322 $ 692,212 $ 3,461,065
15
George Mason’s Concerns • Post Docs & Research Faculty – Postdoctoral fellowships – Nature of research work – Grant funding • Coaches – Scheduling differences when sport is in/out of season – Self-generated funding • Support Staff – State limitations – Compression – Uncertain overtime
16
Strategy Heather Murray Associate Director of Human Resources
17
FLSA = UFO Gonzaga University is a private, Jesuit institution, non-research and nonunion with slightly over 1,400 faculty and staff • GU-HR’s approach
– UFO = Un-Funded Obligation
• Scope of evaluation:
– Efficiencies—where can we best utilize technology services and recognize changing nature of work – Consider additional headcount or something must give – Consider salary increase to threshold to remain exempt classification— with a formal position re-evaluation and only if cost is manageable – Change position’s classification to non-exempt and incur the potential OT
18
Impact Analysis
• Do not lose sight of intent of the law • Long-term impact—inflating market data • Find balance between work expectations and quality of life • OT is a controllable expense • Set policy on what constitutes reasonable OT
19
Strategies • Leadership position = no adjusting description or competencies without a formal evaluation to FLSA criteria and benchmark against survey data • Committed to appropriate OT funding—HR partnering with Finance to create a centralized contingency – Formula = 2x of last year’s OT spend – Intent is to manage the $$$ and maintain culture alignment based on University’s mission
• Policy revision—actively discussing potential policy implications – Vacation accrual rates – Travel policy
20
Strategies continued Educate, Educate, Educate • Create a holistic education effort • Develop training for supervisors and individual contributors across all areas on campus • Hold open meetings • Present at departmental meetings • Establish tone of shared responsibility
21
Poll Question Does your college or university have different benefits or perks for exempt and non-exempt employees? Yes No
22
Morale John Whelan Associate Vice President and Chief HR Officer
23
Morale Indiana University is a public research university with 114,000 students and 23,000 faculty and staff members on eight campuses • Identify changes to impacted employees
– Pay, work schedule, benefits, perceived status, career concerns, certifications, etc.
• Assess emotional reactions or impact to morale – What are the most sensitive issues?
• Communicate
– Lead rather than react – Explain facts and rationale, but empathize – Caution—audience is more than just impacted employees – Role for more than just compensation person(s)
• Avoid unnecessary complications
– If possible, decisions should not be strictly financial
24
Poll Question In which area of your institution do you anticipate the biggest impact to occur? Student Affairs/Services Administrative Athletics Admissions Other
25
Community College Challenges Linda Peltier Executive Director of Human Resources
26
Addressing the challenges of the new OT regulations Edison State Community College is a two-year public institution with 143 faculty and staff serving 2,700 students • Are your job descriptions up-to-date to include current exempt or non-exempt status? – In 2009 Edison implemented a new grade/salary structure which has enabled us to keep our job descriptions up-to-date
• Which positions are going to be impacted?
– At Edison, the areas impacted the most are the coordinators/directors of: • Financial Aid • Athletics/Student Life • Marketing • Student Affairs/ • Library • Human Resources Admissions • IT
• What about the budget and preparing for our July 1st fiscal year? – The lowest annual salary of employees impacted in this group is $34,657 – The new regulations will impact 26 of our 47 professional/technical employees, elevating our non-exempt number from 31 to 57 – No, our budget cannot accommodate increasing their annual salaries to meet the new threshold!
27
How To Prepare Establishing a plan • In assessing the positions, some will only be impacted during high enrollment times and at the start of each semester. We will control some of this through flex time. Other positions like our Director of Financial Aid, Director of Athletics/Student Life, and IT positions will have more of a budget impact due to the necessity of working overtime – Tracking OT hours will be foreign and cumbersome for these employees – Supervisors will need to estimate the projected OT hours/costs to be presented during their budget planning process
• Taking into consideration the total compensation package, it is not an option for our budget to add positions. It is more feasible to pay the overtime. The challenge will be to assure that it is applied consistently across campus • Strengthen our policies and procedures to make sure that employees know the specific guidelines for working overtime. One of the primary focuses will be on reading and responding to e-mails after hours and on weekends • Change is not easy, therefore, communication and training is going to be essential with accountability being an important piece 28
Community College Challenges continued Ricardo Coronado Associate Vice Chancellor for Human Resources
29
FLSA Salary Exemption Pay Level Tarrant County College is a comprehensive two year institution with over 50,000 students across six major campuses • Current Salary Range Level for Exempt Employees
– Lowest Class Code (Pay Grade 15) for Professional Staff including part-time – Lowest Class Code for 12- month Continuing Education Instructors – Exempt Pay Starts at $46,792
• New Proposed Min. Salary for Exempt Employees – New Min. Exempt Pay will increase to $50,440
30
FLSA & Pay Implications • Budget implications for salary and fringe benefits. Estimated Cost: $305,552, not including new hires coming in (Class Code 15 - 96 FT and 45 PT) • May cause salary compression and pay equity issues with the class code (pay grade and salary ranges) above it. Estimated Cost: $126,665 – 36 FT and 10 PT • This will impact a small number of our full-time 12-month Continuing Education Instructors. Their pay is significantly lower than the new threshold of $50,440. Estimated Cost $176,655 – 20 FT and no part-time impacted • Tarrant County College is fortunate to have positioned itself to have a higher annual salary for all of its salaried, exempt employees than most of the other community colleges. We are in a highly competitive market, able to pay, and have maintained a good market position. Total Estimated Cost: $608,872 31
Compliance John Whelan Associate Vice President and Chief HR Officer
32
Compliance—Issues • We already do this, what’s the big deal? • FLSA classification normally determined before employees are hired into role
– Supervisors and employees understand expectations and work parameters (mostly…)
• Switching existing employees from exempt to non-exempt may mean big changes – Work schedule, 9-5, cell phone, emails, tracking hours, etc. – Need to do more with less – Technology makes this a greater challenge
• May be perceived “Lose – Lose” by supervisor and employee – Temptation to ignore
33
Compliance—HR Role • Educate supervisors and employees
– Start with basics – how OT works, tracking time, comp time, etc. – Employee can’t opt out of OT pay (we know this, but now it may be tested more than ever) – Impact to the institution if not compliant
• HR has opportunity to be “strategic partner” – Workforce planning – Coaching – OD
• Plan to do audit and course correct if necessary (before DOL decides to!)
34
Poll Question How likely are you to take action to prepare for the proposed FLSA regulation changes in the next 4 – 6 weeks? Unlikely Somewhat Likely Likely Very Likely Definitely 35
Questions/Answers
36
FLSA Overtime: How, When and Why to Prepare
Thank you! Sponsored by
February 16, 2016
