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DOL Issues Six Opinion Letters Clarifying Overtime, Commissions, and FMLA Leave

The guidance prompts employers to reassess compliance across pay, bargaining agreements, leave accounting.

Overview

  • Non‑discretionary performance bonuses must be included in the regular rate for overtime, requiring recalculations when bonuses are triggered by objective criteria.
  • Mandatory pre‑shift roll calls count as hours worked and must be paid, with only narrow partial overtime exemptions potentially available under FLSA Sections 7(b)(1) or 7(b)(2) if a CBA meets statutory conditions.
  • Licensed clinical social workers with master’s degrees performing advanced clinical duties may qualify for the learned professional exemption only if paid on a salary basis at or above the FLSA threshold, and employers may still opt to classify such roles as non‑exempt.
  • For the retail/service commissioned‑employee exemption under Section 7(i), the minimum is 1.5 times the federal minimum wage ($10.88) and more than half of pay must be commissions, with tips counting as compensation only when a tip credit is taken.
  • FMLA leave accounting is clarified to exclude partial‑week business closures from reducing intermittent leave, and reasonable travel time to and from medical appointments may be charged as FMLA leave.