DEVELOP A COMMUNICATIONS PLAN TO PREPARE FOR THE UPDATED EXEMPT SALARY THRESHOLD

By October 9, 2019 November 4th, 2019 Blog, Newsletter

In last month’s article about the updated exempt salary threshold, we reviewed job descriptions, job duties and exempt versus nonexempt positions. Now let’s develop a communication plan, anticipate issues, and educate managers and the newly nonexempt about their timekeeping procedures.

Develop a communication plan

Remember the saying, “it’s not what you say but how you say it”? In this case, “I want you to think about both.”

If your organization enacts change related to the new exempt salary threshold, management needs to actively relate those changes to staff. Specifically, ensure that communications are dialogues rather than one-sided press conferences.

This may be a complicated situation. Most of us don’t like change, especially when the change is perceived as negative. It’s essential for your management team to have a consistent message as you roll out the changes and as staff ask questions. You need a robust and clear vision going forward.

If you haven’t started talking with your managers and supervisors, do it now. Figure out how you’ll communicate the upcoming changes, whether you’re increasing salaries to meet the new threshold, reclassifying positions, or a combination of both.

You may want to designate a primary contact person for all questions. However, I also encourage you to prepare management with information. Get their input and creative ideas for developing a clear vision. Consider preparing a document that explains the changes’ “what, why, how, and when,” to share with affected employees.

Give your managers and supervisors opportunities to ask anticipated questions and consider role-playing to help them find positive responses. Empower your managers with knowledge and encourage them to positively communicate your changes. The managers’ handling could make or break how the transition is received.

I suggest having meetings, now, to reduce surprise and to give a “heads up” to impacted employees. Briefly review, recap, and explain the salary threshold change. Clarify that the salary level was increased significantly, and you can’t or may not be able to improve everyone’s salary to comply.

Let employees know that these standards are set by the federal government and not by your organization. This isn’t personal. Although some may feel that it is, it’s the law.

Explain that everyone’s working hard to figure out the best possible way forward, whether it’s by increasing salaries to comply with the new threshold, or by reclassifying some positions. Solicit staff input as you did with the managers. Your employees know their jobs best and may have terrific ideas.

Anticipate issues

Some employees’ self-esteem may be triggered when moving from a salary to an hourly pay structure. They may feel less valued, which could lead to increased turnover. Identify employees who are risk of quitting because of this change.

Also keep in mind:

  • The perception of a demotion. Employees whose jobs are reclassified may feel less trusted. You must clearly communicate that the change to how they are paid, for all hours worked, is solely related to their pay calculation method. Be sure to express that you appreciate their continuing hard work and dedication, on behalf of your clients, organization, and mission.
  • Will you need to modify your organization’s benefits plans? How do you define who receives benefits and who doesn’t?
  • Will timekeeping practices and systems need to change?
  • How will changes to compensation structure affect internal equities for the employees above and below your current exempt employees’ pay?

Be prepared. Be sensitive.

Follow up and ask for advice as the process rolls out. Keep lines of communication open. Recognition is crucial in times of change.

Training and education for managers and for those that are newly nonexempt

You may soon have employees who haven’t been paid hourly for years or decades. You may also have managers who have never supervised hourly employees. Examples of critical areas of education for employees and managers include:

  • When is overtime earned? Daily? Weekly?
  • Do you know your state meal and break laws?
  • Who must take meals and breaks?
  • What about timecards and tracking hours worked?

Note that states with meal and break laws are very particular about duration and also when they should be taken within the workday – for example, never in the first or last hour of work.

Explain the new timekeeping procedures. 

One of the most challenging adjustments for the newly nonexempt is having to track their time down to the minute or within a few minutes. They will need to ensure that they correctly record all time worked. You should explain that the reason is due to federal regulations and not a discretionary decision made by your organization. Employers are bound by law to keep track of the nonexempt employees’ time worked. Everyone should be very clear of this requirement.

Habits are hard to change. Newly nonexempt employees may find it hard to adjust their work routines and learn to be more efficient. It’s challenging to change habits we’ve had for years, such as working through lunch, checking work emails after work hours, or taking evening work-related phone calls.

Supervisors should make it a point to walk around daily, and check timecards, to ensure nonexempt employees aren’t working through meal periods or staying late. Please be careful with your approach to checking timecards. You want the timecard check to be a positive job requirement instead of an exercise in “Big Brother.”

Supervisors, be aware of your employees’ work habits to avoid unanticipated program increases or departmental wage costs. Nonexempt employees must be paid for all time worked, whether or not the supervisor explicitly authorized the time.

If habitual “offenders” are logging extra time out of habit, supervisors should speak to them immediately about adjusting their routines. If employees are struggling to meet workload demands, redistribution of work or rescheduling may be in order.

Excellent communication is the key to a positive work environment. Open dialogue is also useful for spotting, understanding, and resolving issues as they arise. Let’s be patient together and give everyone the time needed to adjust.


501(c) Agency Trust memberships or subscribers of HR Services may contact us at (800) 358-2163 or at HRServices@501c.com for any questions you may have about wage and hour, or any other HR situation. You may also visit our resource library at www.knowledgebase.501ctrust.org.

The purpose of this article is to review the latest developments in human resource matters. The information contained herein has been abridged from numerous sources and should not be construed as legal advice or opinion, and is not a substitute for the advice of counsel.

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