Last
week
a
Department
of
Labor
(DOL)
official
announced
that
the
much-anticipated
changes
to
the
overtime
pay
rules
may
not
be
published
until
late
2016.
That’s
not
a
typo—she
really
did
say
2016.
But
the
flip
side
is
that
the
rules
will
become
effective
shortly
after
they
are
published.
So
employers
would
be
wise
to
start
mapping
out
their
potential
compliance
strategy
now,
rather
than
waiting
until
the
final
regulations
actually
drop.
As
you
are
probably
aware,
this
past
June
the
DOL
issued
a
proposed
regulatory
change
to
the
“white
collar”
exemptions
to
the
minimum
wage
and
overtime
requirements
of
the
Fair
Labor
Standards
Act
(FLSA).
The
proposal
is
to
increase
the
minimum
salary
that
must
be
paid
to
employees
to
be
exempt
(from
the
minimum
wage
and
overtime
requirements
of
the
FLSA
)
for
most
of
the
“white
collar”
exemptions
from
$23,660
annually
($455
per
week)
to
$50,440
($970
per
week)
with
annual
automatic
increases
thereafter.
This
change
will
apply
to
all
employers
with
white
collar
exempt
employees,
private
or
public
sector,
profit
or
not-for-profit.
Since
June
30,
the
Department
has
received
more
than
250,000
public
comments,
which
it
is
obligated
to
consider
before
issuing
a
final
rule.
In
early
November,
the
Solicitor
of
Labor,
Patricia
Smith,
said
the
final
rule
likely
will
not
be
published
until
the
fall
of
2016
with
an
effective
date
as
soon
as
30-60
days
after
publication.
Most
commentators
believe
that
the
Department
wants
the
new
rule
to
be
effective
before
the
November
2016
general
election.
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