Impact of Proposed Overtime Rule on IEC Members
In 2019, the overtime salary threshold was changed to $35,568 per year, or $684 per week. How did your organization respond to this change? (Check all that apply)
We reclassified employees to nonexempt (hourly) status
We raised exempt employees’ salaries to meet the new threshold
We restructured employees’ job duties
We made no significant changes
At what salary level would your organization likely consider reclassifying exempt employees to nonexempt status or restructure jobs?
Any increase from current level
What are some potential challenges your organization may face if a higher salary threshold were implemented? (Check all that apply)
Reduction in opportunities for professional development
Diminished workplace autonomy
Time to review all job descriptions
Time to communicate and train staff on changes
Do not anticipate any negative impacts
What are some workplace changes instigated by the COVID-19 pandemic that DOL should consider when implementing a new overtime salary level? (Check all that apply)
Increased reliance on remote work for exempt employees
Increased allowance for flexible work hours for exempt employees
Cut budgets and higher costs to operate
The FLSA specifically requires the Department to update the tests for exemptions from “time to time” and “by regulation.” In the past, DOL has considered automatically updating the salary threshold at set intervals (e.g., every 3 years), and DOL has included a 3-year update provision in this proposal. How do you think DOL should approach increases to the salary threshold?
DOL should institute automatic updates
DOL should evaluate the economic circumstances and take comments from the public through rulemaking each time it considers updating the exemptions
From 1938 to 1975, DOL updated the minimum salary level every five to nine years. Prior to 2019, the last update to the minimum salary level was in 2004, or 15 years prior. How frequently would it be reasonable to increase the minimum salary level for exempt status, whether it be automatic or through the formal rulemaking process?
More than 9 years