On July 1, 2024, the Department of Labor’s final rule on exempt employee compensation thresholds went into effect. Each of the regulations sections 541.100 (executive employee), .200 (administrative employee), and .300 (professional employee) have been updated to refer to the minimum salary compensation levels now stated in section 541.600.
29 C.F.R. § 541.600 now provides:
To qualify as an exempt executive, administrative, or professional employee . . . , an employee must be compensated on a salary basis at a rate per week of not less than the amount set forth in paragraphs (a)(1) through (3) of this section, exclusive of board, lodging or other facilities, unless paragraph (b) or (c) of this section applies [which are likely inapplicable to TBM]. Administrative and professional employees may also be paid on a fee basis, as defined in § 541.605.
(1) Beginning on July 1, 2024, $844 per week (the 20th percentile of weekly earnings of full-time nonhourly workers in the lowest-wage Census Region and/or retail industry nationally).
(2) Beginning on January 1, 2025, $1,128 per week (the 35th percentile of weekly earnings of full-time nonhourly workers in the lowest-wage Census Region).
(3) As of July 1, 2027, the level calculated pursuant to § 541.607(b)(1).
The threshold for highly-compensated employees is now an amount not less than $132,964.
See DOL Final Rule information here.
It is advisable for employers to evaluate salary compensation levels and job descriptions for employees who are treated as exempt from the overtime and recordkeeping rules applicable to exempt and non-exempt employees. Budgets may also need review and adjustment to accommodate any increased salary levels that may be necessary for compliance with the DOL’s final rule.
For religious organizations, it is a reminder to also review and update job descriptions with a focus on and inclusion of as many of the minister-employee factors as the position’s actual duties will truthfully accommodate in accordance with Hosanna-Tabor Evangelical Lutheran Church & School v. EEOC, 565 U.S. 171 (2012) and its progeny.
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