If you have not audited your exempt employee pay practices for compliance with the federal Department of Labor’s rules announced earlier this year, you have just under two weeks to do so. Starting December 1, 2016, the federal minimum salary thresholds increase for a variety of exempt workers, including under the white-collar exemptions (Executive, Administrative, Professional or salaried Computer Employees) from $23,660 to $47,476 and the Highly Compensated Employee exemption from $100,000 to $134,004. Employees whose salaries fall below applicable thresholds will become non-exempt – regardless of their title and job duties – and thus eligible for overtime under federal law. Please see our May 23, 2106 Employment Alert for further information about the rule and its changes.
In reviewing pay practices, employers should also be mindful that state law may differ, at times providing greater protections to employees, and comply with all applicable state and federal wage and hour laws. For assistance with assessing your workforce and compliance with federal and state wage and hour law, please consult an Employment Practices Group attorney.