DOL Overtime Rule Update
Thank you to Simon | Paschal PLLC for providing this timely update.
Employers have been in a state of partial limbo since this spring when the United States Department of Labor (“DOL”) issued regulations increasing the minimum salary requirement for the executive, administrative, and professional exemptions to overtime pay (otherwise known as the “EAP exemptions” or the so-called “white collar exemptions”). As of Friday, November 15, 2024, the matter has been resolved in favor of employers nationwide.
At the time of the new regulations this past spring, the minimum salary requirement for the EAP exemptions was $684 per week and had been at that level since 2019. The regulations provided three updates to the minimum salary requirements – an increase to a minimum weekly salary of $844 effective July 1, 2024, an increase to a minimum weekly salary of $1,128 effective January 1, 2025, and automatic increases every three years beginning July 1, 2027.
The Bottom Line...For Now
For now, the bottom line is that the DOL’s new rules regarding the minimum salary requirements for the EAP overtimes exemptions are gone and the rules have returned to their previous level. To be exempt from overtime under the executive, administrative, and professional exemptions, in addition to the requirements of the respective job duties tests, an employee must earn a minimum salary of $684 per week.
For those employers that increased salaries to comply with the July 1, 2024 increase, you are free to return those salaries to their July 1, 2024 levels. You may wish to keep the salaries at their new levels for a host of reasons, not least of which is employee morale, but you are able to reduce them if you wish and remain in compliance with the exemption rules.
Read the Full Text
Interested in learning more? Read the full PDF alert here. Thank you to our friends at Simon | Paschal PLLC.
