This is part 3 of 4 HRX posts related to the new federal overtime rule. A helpful FAQ also is available.
By now, many districts have likely begun identifying employees who would be impacted by the new FLSA salary threshold rules slated to go into effect January 1, 2020. As outlined in this previous HRX post on calculating weekly salary, districts have two options to address these employees—raise the weekly salary to meet the $684 threshold or change the employees’ FLSA status to nonexempt. But what next?
Communication will be key
The most important factor to making a smooth transition is to communicate changes in a clear and effective way. Plan ahead and start talking to employees and supervisors about the proposed changes as soon as possible. Sample notices for communicating changes to supervisors and employees are also available to our members in the Compensation and Benefits section of the HR Library.
Conversations should be easy for those whose salaries are being raised and exemption status unchanged, but for those being reclassified as nonexempt, the following tips are recommended:
- Outline their responsibility for monitoring employee work hours and ensuring accurate timekeeping.
- Remind them that they are accountable for controlling and approving overtime.
- Point out that overtime costs will be charged to their budget.
- Ensure the HR administrator conducts the initial discussion and addresses any questions that follow.
- Plan for individual conversations with employees who are impacted.
- Include the supervisor in the initial meeting.
- Stress that the change is because of a change in federal law and not a reflection of the employee’s performance or value to the district.
- Identify job changes, if any, restrictions on working after hours and off the clock, and timekeeping requirements.
- Ensure the employees understand they will need permission to work overtime or to take work home.
It also is important to start working with payroll as soon as possible so they can plan for the transition and determine if any programming changes are needed. Describe the scope of the changes including the number of employees affected and other issues that may arise. For instance, if the district opts to make a part-time employee nonexempt rather than increase pay, it’s possible to end up with both exempt and nonexempt employees in the same job classification.
Additionally, don’t forget to provide an overview of the upcoming changes to the board. Key points to communicate include the number of employees impacted, potential cost increase if any, and that the change is a result of federal law.
Read more in Part 4: Timelines and Logistics. View previous posts on the subject in the HR Laws section of the HRX archive, including a helpful FAQ. General guidance and an FAQ section are also available through the Department of Labor.
Erin Kolecki and Keith McLemore are Compensation and HR Consultants at TASB HR Services. Send Erin or Keith an email at email@example.com or firstname.lastname@example.org.
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