FLSA Compensation Threshold Increases - Supervisors Guidance

Salary thresholds defined under the Fair Labor Standards Act will update every three years based on up-to-date wage data. Human Resources, Payroll Services, and the Office of Budget and Planning will work with you as necessary to plan for and provide guidance for these changes.

This webpage is a general reference for University supervisors. Please work with your Senior HR Partner to plan for any impacts to your unit or direct reports.

2024 FLSA Compensation Threshold Increases

On April 23, 2024, the Department of Labor (DOL) announced planned updates to the Fair Labor Standards Act compensation threshold, one factor in determining whether a position can be exempt from overtime requirements.

If the following upcoming minimum thresholds are above your salary, you may be impacted.

July 1, 2024: $844 weekly ($43,888 annually)

Jan. 1, 2025: $1,128 weekly ($58,656 annually)

New Threshold Impact on Supervisors

An increase to the FLSA salary threshold means that direct reports who are paid under the new salary threshold and who meet the FLSA duties requirements will automatically convert from salaried to hourly, become positive time reporters, and be entitled to FLSA protections, including overtime pay or compensatory time accrual.

Due to the financial impact of overtime pay on a unit’s budget, it is your responsibility to consider rescheduling priorities, reassigning work, rebalancing workloads, or offsetting hours during the same workweek before approving overtime hours.

Tips for Supervisors

  • Meet with impacted direct reports to ensure they understand overtime policies, procedures and expectations.
  • Check with department leadership to confirm expectations regarding meal and break times or compensatory time accrual.
  • Before authorizing overtime, explore all alternatives, such as changing priorities, reassigning work, or offsetting excess hours with reduced hours in another day in the same workweek.
  • You and your business office will receive notifications if your direct report exceeds the max comp time accrual balance of 120 hours. College/division leadership may grant an exception for up to 240 hours, but please be mindful of your employees' balances.
  • The Time and Labor: Supervisor Responsibilities training has been updated. Consider retaking it as a refresher.

Resources for Supervisors

Managing Hourly Employee Overtime

Please visit the Salary vs Hourly webpage to learn about overtime and compensatory time.

Supervisors CAN

Image
Supervisors Can Overtime

Require employees to work more than their regular hours in a workweek.
Prohibit employees from working more than their regular hours
Require employees to receive approval before working more than their regular hours in a workweek, which may include corrective or disciplinary action if they do not.
Request that employees be compensated with either compensatory time accrual or cash payment.
Prohibit or limit paid rest periods if not established department, college, or division practice.

Supervisors CANNOT

Image
Supervisors Cannot Overtime

Ask employees to clock out and continue working.
Pressure employees into an unspoken "don't ask, don't tell" situation in which they implicitly know they are expected to work more than their regular hours without overtime pay (e.g., answering emails/calls after hours).
Prevent employees from being compensated for overtime, even if they worked more than their regular hours without prior approval. 
Make it more difficult to use compensatory time compared with other accrued time off. 
Require employees to work an 8-hour workday without an uninterrupted meal period of at least 30 minutes (unless there is a specific departmental exception).

Frequently Asked Questions

Human Resources will contact employees and their supervisors via email leading up to the change date.

In addition, the UAccess Analytics FLSA Impact Report is available with "HR Medium" provisioning. You may also contact your Senior HR Partner for assistance locating impacted employees in your area.

Determining exemption status may be challenging based on FTE, stipends, allowances, etc. You do not need to navigate or calculate on your own. Human Resources is here to support you. If you have questions, please contact your Senior HR Partner.

Yes, an employee may shift hours around within a given workweek to stay within their regular hours. In fact, as a supervisor, you must explore all options to facilitate this before considering overtime. This may include rescheduling priorities, reassigning work, re-balancing workloads and even revising the employee’s work schedule so that weekend work is performed as a regular part of the workweek.

You may not shift hours across weeks.

Generally, it is not appropriate to set or change salary to avoid FLSA regulations. It is also not necessary for colleagues doing similar work to all have the same exemption status, even if they have the same title, job function/family or career level.

However, certain positions may have large fluctuations in workload based on seasonality or project cycles or receive allowances and stipends, which can cause budgetary or other logistical considerations for units. Please contact your Senior HR Partner to work through individual situations and strategize options.

Yes. Categories of employment outlined in the Fair Labor Standards Act and Overtime Policy “Exemption Tests” section (Department of Labor Fact Sheets 17A-E and S) are exempt from FLSA regulations.

If you have questions about the exemption status of a direct report or planned new position posting, please contact your Senior HR Partner.

For questions regarding specific situations about how various compensation elements (allowances, stipends, OPS and more) affect FLSA exemption status of a position, please contact your Senior HR Partner.

If an employee has concerns rooted in perceptions of status, prestige or value of their position
FLSA regulations are designed to protect employees and ensure they are fairly compensated. However, until the 2024 changes by the Department of Labor, the salary threshold had not kept up with rises in salaries and inflation for many years. As a result, hourly work has unfortunately come to be associated with entry-level or lower responsibility work.

It is important to try and modernize this type of perception. FLSA exemption status does not affect an employee’s FTE, career architecture mapping, benefits and retirement or accrual of time off.

If an employee has concerns rooted in understanding when overtime is allowed or required
As the supervisor, you and your unit determine overtime expectations and requirements for employees. Please be open and transparent with hourly employees about those expectations and guidelines. 

If an employee has questions about how to report time
Please refer employees to the following resources:

Every state complies with the federal FLSA requirements. However, some states extend or supplement those regulations. This is one of the reasons that there are additional processes for hiring employees outside the state of Arizona, as defined in the Out-of-State Domestic (U.S.) Work Arrangement Guidelines.

Please do not feel obligated to try to navigate and understand multiple state regulations. Allow Human Resources to advise and conduct a compliance review of state regulations. Contact your Senior HR Partner for guidance.

Do you need more assistance? 

Connect with Payroll Services
Phone: 520-621-9097
Email: FNSV-Payroll-Info@arizona.edu