Comment on WA Overtime Pay Policy Options

July 30, 2018

Washington State’s Department of Labor and Industries is currently engaged in rulemaking to update our state’s overtime pay exemption threshold. The likely effect of this process is that more workers will be eligible for overtime pay, which will undoubtedly impact your nonprofit organization. Because of this, we strongly encourage your organization to join Washington Nonprofits in responding to the latest Draft Rule Concepts released by the Department before September 5th. Comments from Washington Nonprofits are available here.

The full set of draft concepts is available here. It contains a menu of policy options for your organization to consider and comment on.

Part A in particular is critical: it lays out proposed salary exemption thresholds for overtime pay tied to a number of factors. This is an opportunity for your organization to analyze what the proposed levels mean for your employees, operations, and services. Be sure to engage your finance staff, accountants, and others when weighing the options. For reference when considering Part A, the current federal overtime pay exemption threshold from the U.S. Department of Labor is $455 per week/$23,000 per year. In 2016, the Obama Administration proposed raising the exemption threshold to $913 per week/$47,476 per year.

We know that many of your organizations planned to adjust your staffing and business models to comply with the Obama Administration’s proposed expansion of overtime pay in 2016. We recommend that your organization revisit any analysis, planning, or forecasting that you conducted in 2016 to inform your comments to the state on this issue.

Responses to the Draft Rule Concepts can be submitted here before September 5th.

Responding to the Department’s questions is your chance to shape the threshold and make sure nonprofit voices are heard during this process. Washington Nonprofits is part of the stakeholder group participating in the feedback process and we plan to submit comments on this latest request before the deadline. You can view our previous responses to help inform your comments:

  • Our Round 1 comments are here
  • Our Round 2 comments are here
  • Our Round 3 comments are here
  • Our Round 4 comments (this round) are here
Please feel free to contact us if you have any questions or would like to discuss this issue.

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