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CIRT Comments on DOL Salary Threshold Rulemaking

Tue, November 07, 2023 9:58 PM | Anonymous member (Administrator)

CIRT submitted a comment on the Department of Labor, Wage and Hour Division’s proposed rule nearly doubling the “salary threshold” required to meet the exemption from requirements for hourly/overtime status.  CIRT pointed out that “This is a particularly inopportune time to suggest a major across the board hike in the salary threshold – particularly given the recent substantial increase a few years ago (which DOL has failed to show any reason to renew), and the potential to continue or fuel an inflationary spiral that higher wages my ignite or prolong in the U.S. economy.”  Moreover, the Round Table also pointed out that what appears to be the Wage & Hour Division’s intent i.e., to ensure that middle class jobs pay middle class wages [by] extending important overtime pay protections to millions of workers and raising their pay;” -- is wholly beyond the Wage & Hour Division’s authority.

CIRT emphasized that the “salary” portion of the exemption test is a THRESHOLD salary level, NOT an attempt to set what “should” be the salary for employees by the Department. . .  That task rightfully and appropriately belongs to the private sector firms to determine given market, economic, regional, industry, company, and competitive norms.

For details, see attached CIRT’s Comment Letter.

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