News & Analysis as of

Opinion Letter Wage and Hour

Fisher Phillips

Return of the PAID Program: Here’s What Employers Need to Know as DOL Reinstates Back Wage Payment Option

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The US Department of Labor’s latest update rewards employers that proactively resolve potential wage and hour claims and obtain approval of their investigation and resolution. The DOL’s Wage and Hour Division first introduced...more

Bass, Berry & Sims PLC

DOL Announces Enforcement Position on Independent Contractor Rule

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On May 1, the U.S. Department of Labor (DOL) issued a Field Assistance Bulletin announcing that the Wage and Hour Division (WHD) will no longer enforce the 2024 independent contractor Final Rule previously established by the...more

Conn Maciel Carey LLP

Leadership Updates and a New Opinion Letter Program Confirm the U.S. Department of Labor’s Increased Focus on Compliance...

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The U.S. Department of Labor (“DOL”) recently named several political appointments to its Wage and Hour Division (“WHD”). Employers know WHD is an entity with vast enforcement authority, including over minimum wage and...more

Fisher Phillips

DOL Reboots Opinion Letter Program to Offer Guidance on Wage and Hour, Workplace Safety, and More

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The US Department of Labor just relaunched and significantly expanded its opinion letter program, offering employers across five enforcement agencies a direct line to legal interpretations of federal laws on wage and hour,...more

Seyfarth Shaw LLP

“Dear DOL”: Labor Department Re-Launches Opinion Letter Program

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In a welcome development for employers navigating complex federal employment laws, the U.S. Department of Labor has announced the re-launch of its opinion letter program across several agencies, including the Wage and Hour...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Department of Labor Announces Expansion of Interpretation Letters Initiative

On June 2, 2025, Deputy Secretary of Labor Keith Sonderling announced a renewed and expanded commitment by the U.S. Department of Labor (DOL) to the issuance of interpretation letters—commonly referred to as opinion letters...more

Nilan Johnson Lewis PA

Department of Labor: Managers Must Keep Their Fingers Out of the Tip Jar – Even When They Helped Earn the Tips

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The DOL Wage & Hour Division issued its first Opinion Letter of 2025 (FLSA2025-1) on January 14, 2025, stating that managers and supervisors, no matter their duties during a particular shift, cannot participate in employee...more

Bowditch & Dewey

Recent Shifts in Wage and Hour Law – Paid Time Off During FMLA Leave and Exempt Employee Status Challenges

Bowditch & Dewey on

January brought two legal updates in the wage and hour space. Read on! PROHIBITING THE MANDATORY USE OF PAID TIME OFF DURING CERTAIN FMLA LEAVES - On January 14, 2025, the U.S. Department of Labor’s Wage and Hour...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

DOL Clarifies That Managers and Supervisors Can’t Wear Two Hats When It Comes to Tips

On January 14, 2025, the U.S. Department of Labor (DOL) issued Opinion Letter FLSA2025-1 pertaining to managers’ participation in a tip pool at a “quick service restaurant.” ...more

Vedder Price

DOL Reaffirms That Managers And Supervisors May Not Participate In Tip Pools

Vedder Price on

On December 18, 2024, the DOL issued opinion letter FLSA2024-02, reaffirming its position that managers and supervisors are prohibited from participating in tip pools under any circumstances....more

Perkins Coie

DOL Clarifies Daily Expense Reimbursement Payments and Exclusions from Regular Calculations for Overtime Pay

Perkins Coie on

The U.S. Department of Labor’s Wage and Hour Division (WHD) recently issued an opinion letter addressing whether daily expense reimbursement payments can be excluded from an employee’s regular rate when calculating overtime...more

Steptoe & Johnson PLLC

Participation in Clinical Trial is FMLA-Protected, DOL Says

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On November 8, the Department of Labor (DOL) issued an opinion letter addressing an interesting question under the Family and Medical Leave Act (FMLA): Can an employee take FMLA leave to participate in a clinical trial for...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

DOL’s Wage and Hour Division Weighs in on FMLA Use for Clinical Trials

In an opinion letter dated November 8, 2024, the Wage and Hour Division of the U.S. Department of Labor (DOL) responded to a question posed by an organization dedicated to finding a cure for specific diseases. ...more

Jackson Lewis P.C.

DOL Opinion Letter Addresses Expense Reimbursement and Regular Rate

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The U.S. Department of Labor (DOL) has released an opinion letter addressing whether per diem expense payments for tools and equipment may be excluded from the hourly rate when calculating overtime pay under the Fair Labor...more

Fox Rothschild LLP

What Is Included In The Regular Rate For Overtime Calculation? The Ninth Circuit Weighs In

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I am always interested in cases that analyze what payments should and should not be included in the regular rate. These issues are important to employers because their overtime liability/exposure can be dramatically inflated...more

Steptoe & Johnson PLLC

DOL Says Holiday Weeks Could Be a Potential FMLA Land Mine

Steptoe & Johnson PLLC on

For many, Labor Day weekend represents the last bastion of summer. It also ushers in a season of holidays, celebrations, and shortened workweeks throughout fall and winter. However, employers that deal with the year-round...more

Jackson Lewis P.C.

What Retailers Can Take Away From Labor Department Opinion Letter on FMLA Leave and Holidays

Jackson Lewis P.C. on

The Wage and Hour Division of the Department of Labor (DOL) has advised in an opinion letter on calculating Family and Medical Leave Act (FMLA) leave when employees take off part of a week during which a holiday falls that...more

Perkins Coie

US Department of Labor Clarifies Calculation of FMLA Leave on Holiday Weeks

Perkins Coie on

The U.S. Department of Labor issued an opinion letter on May 30, 2023, clarifying how employers should calculate Family and Medical Leave Act (FMLA) leave taken by employees “during a week that includes a holiday.” The letter...more

Polsinelli

Department of Labor Issues Guidance on FMLA Leave during a Week with A Holiday

Polsinelli on

Just in time for the summer holidays, the United States Department of Labor (“DOL”) recently issued an opinion letter providing guidance regarding calculating the amount of leave used when an employee takes federal Family and...more

Stevens & Lee

DOL Clarifies How Holidays Impact Partial Weeks Taken Under FMLA

Stevens & Lee on

On May 30, 2023, the Department of Labor (DOL) released an opinion letter clarifying how holidays impact FMLA. Whether the holiday time counts against FMLA depends on two factors: 1.Whether the employee took a partial week...more

Fisher Phillips

Can You Include Sushi Chefs — and Other Unique Positions — in Your Tip Pool? 5 Key Questions for Restaurateurs to Review

Fisher Phillips on

Do you utilize a tip pool in your restaurant? If so, you are likely aware of the various rules on maintaining a valid, lawful tip pool under the federal Fair Labor Standards Act (FLSA) and applicable state laws. You surely...more

Fox Rothschild LLP

Spring Ahead, Fall Back, Pay Now, Pay Later: Daylight Savings Time And The FLSA

Fox Rothschild LLP on

This Sunday was Daylight Savings Time and we pushed the clocks ahead by one hour. This is, on a human level, a welcome event, as it signals winter’s end. Now, I can fling away any vestiges of Seasonal Affective Disorder and...more

Fox Rothschild LLP

Biden DOL Withdrawal Of Trump DOL Opinion Letters Signals Major Pendulum Swing Towards Employees

Fox Rothschild LLP on

I have often said that the USDOL is a politically charged industry and its view on legal issues (much like the National Labor Relations Board) shifts with the Administration that is in power. For example, under the prior...more

Smith Anderson

Independent Contractor Status Under the FLSA Being Reviewed by Biden DOL

Smith Anderson on

The Department of Labor (DOL) under the Biden administration is reviewing and perhaps reconsidering the final rule promulgated by the Trump administration DOL entitled, "Independent Contractor Status Under The Fair Labor...more

Benesch

Department of Labor Withdraws Gig Economy Opinion Letter that Supported Independent Contractor Classification

Benesch on

On February 19, 2021, the Department of Labor’s Wage and Hour Division withdrew its opinion letter that indicated gig economy workers who offer services in a virtual marketplace are independent contractors. The Wage and Hour...more

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