The FLSA was passed back in 1938, but you might say that compliance has never been more “in style” than it is today. If you think your company is in need of a wage and hour “make-over” this year, consider discussing these 10 action steps with your attorney:
- Audit job positions classified as exempt.
- Audit workers classified as independent contractors.
- Develop or audit policies to expressly prohibit unlawful pay practices (e.g., improper deductions, “off the clock” work).
- Develop or audit the complaint mechanism for reporting improper salary deductions and other paycheck errors.
- Develop or audit time-keeping procedures for all non-exempt employees.
- Develop or audit accountability measures such as disciplinary policies for failure to abide by time-keeping procedures.
- Develop or audit procedures for correcting paycheck errors.
- Assess industry-specific pay practices for wage and hour law compliance (e.g., tip pooling arrangements, compensation for donning and doffing protective gear).
- Train managers and non-managers on wage and hour policies and procedures.
- Schedule annual and new hire trainings for all employees.
These action steps were prepared by Bruce J. Kasten and Natalie F. Hrubos for the 2013 annual Spring Seminar series presented by Duane Morris’ Employment, Labor, Benefits and Immigration attorneys.
Stay tuned for announcements about seminar and webinar opportunities in 2014.
Happy New Year!
This blog should not be construed as legal advice, as pertaining to specific factual situations or as establishing an attorney-client relationship.
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