Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before...

Coates Canons Blog Deductions for the Cost of Training under the FLSA

By Diane Juffras

Article httpcanonssoguncedup=7934

This entry was posted on December 10 2014 and is filed under Compensation amp Benefits Employment Fair Labor Standards Act Featured Posts On Employment Law General Local Government (Miscellaneous)

Few things are as aggravating to local government employers as paying for the cost of an expensive training program only to have the employee leave immediately to go to work for another local government employer The new employer gets the benefit of the training for which the old employer paid Small and rural cities and counties commonly suffer this loss among their entry-level law enforcement and firefighter ranks Can local governments recoup the cost of training from employees who leave soon afterward It seems only fair But is it lawful

Background

The federal Fair Labor Standards Act governs the payment of wages to local government employees Generally money may not be deducted from the wages of exempt employees (who are paid on a salaried basis and do not get paid overtime) without destroying the exemption Amounts may not be deducted from the wages of nonexempt employees if the amount deducted would bring the employeersquos pay below the minimum wage or cut into their overtime pay

There are however exceptions to these generally stated rules Take for example the overpayment of wages When an employer has accidentally paid more than it owes an employee in wages it may deduct the amount of overpayment from the employeersquos wages either in a lump sum or over time This will not destroy the exemption of an exempt employee For nonexempt employees the US Department of Labor has said in a Wage and Hour Opinion Letter ldquothe principal may be deducted from the employeersquos earnings even if such deduction cuts into the minimum wage or overtime pay due the employee under the FLSArdquo A decision to advance wages to an employee is treated in the same way

Isnrsquot paying the cost of an employeersquos specialized training analogous to an overpayment or advance on wages Many local governments seem to think so They have adopted policies requiring police officers or firefighters to repay a portion of their training costs if they voluntarily leave before completing a specified number of years of service

Deducting the Cost of Training Appears to Be Lawful

Given how frequently this issue arises here in North Carolina I have been surprised to find no regulatory guidance and very few judicial decisions that address the lawfulness of deducting the cost of training Neither the US Department of Laborrsquos FLSA regulations nor any federal Fourth Circuit Court of Appeals or North Carolina federal district court cases address deductions for the cost of training Two cases from other circuits however provide a rationale for allowing such a practice

Viewing Payment of the Cost of Training as a Loan

In the 2002 federal Seventh Circuit Court of Appeals case Heder v City of Two Rivers Wisconsin the city funded its firefightersrsquo mandatory paramedic training but required a firefighter to reimburse the city for the costs of training if the firefighter left before completing three years of service The Seventh Circuit upheld the reimbursement agreement comparing it to a loan the cost of the training was a loan the city made to its firefighters repayment of which was forgiven after three years If however a firefighter left before three years of service the loan became due The court held that as long as the city paid departing firefighters at least the statutory minimum wage it could deduct the training costs from wages

In a 2010 decision from the federal Ninth Circuit Court of Appeals Gordon v City of Oakland the Ninth Circuit adopted similar reasoning in holding that a cityrsquos deduction of the cost of training from an employeersquos final paycheck was lawful The court noted that the city could choose to require applicants to obtain their police training independently prior to

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beginning employment which the city could do by hiring only individuals already possessing law enforcement certification Instead the city elected to make what was essentially a loan to police officer trainees of the cost of their police academy training In this case the conditional offer the plaintiff signed explained that the city would forgive her repayment obligation at a specified rate and that she would owe nothing after five years of service Because the plaintiff chose not to serve the five years necessary to secure complete loan forgiveness the city was the plaintiffrsquos creditor Because it satisfied the FLSArsquos requirements by paying her at least minimum wage for her final week of work it did not violate the law

Conclusion

Based on the Heder and Gordon decisions it appears that the deduction of the cost of an employeersquos training from his or her paychecks is permissible so long as employees are advised of the policy at the outset of employment and the deduction does not bring the employeersquos regular rate of pay below minimum wage

For more on deductions from employee wages see Bob Joycersquos January 4 2011 post Public Employer Withholding from Last Paycheck at httpcanonssoguncedup=3750

Links

wwwdolgovwhdopinionFLSANA20042004_10_08_19FLSA_NA_recouppdflawresourceorgpubuscasereporterF3295295F3d77701-4118htmlcasetextcomcasegordon-v-city-of-oakland-2

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Copyright copy 2009 to present School of Government at the University of North Carolina All rights reservedThis blog post is published and posted online by the School of Government to address issues of interest to government officials This blog post is for educational and informational use and may be used for those purposes without permission by providing acknowledgment of its source Use of this blog post for commercial purposes is prohibited

To browse a complete catalog of School of Government publications please visit the Schoolrsquos website at wwwsoguncedu or contact the Bookstore School of Government CB 3330 Knapp-Sanders Building UNC Chapel Hill Chapel Hill NC 27599-3330 e-mail salessoguncedu telephone 9199664119 or fax 9199622707

This blog post is published and posted online by the School of Government to address issues of interest to government officials This blog post is for educational and informational use and may be used for those purposes without permission by providing acknowledgment of its source Use of this blog post for commercial purposes is prohibited

Coates Canons Blog Are Employees of Seasonal Recreational Establishments Exempt from Overtime

By Diane Juffras

This entry was posted on April 15 2015 and is filed under Compensation amp Benefits Employment Fair Labor Standards Act General Local Government (Miscellaneous)

Many local governments hire additional employees for the late spring through early fall months This period sees the opening of municipal and county pools and summer camps increased activity at parks golf courses tennis courts as well as beaches for communities on the coast or on one of North Carolinarsquos many lakes and the need for seasonal workers Which of these employees will be exempt from overtime under the FLSArsquos exemption for employees working at a seasonal amusement or recreational establishment

The Fair Labor Standards Act (FLSA) requires employers to pay employees time-and-one-half their regular rate of pay for all hours over 40 that employees work in a given week unless an employee is exempt under the FLSArsquos salary basis test and one of either the executive administrative or professional duties tests (On the duties tests see here here here here and here) The FLSA also provides for a limited number of other exemptions from overtime for employees who are nonexempt under the duties tests I have discussed two of them in previous posts the 207(k) scheduling exemption for law enforcement officers and firefighters (see here) and the fluctuating workweek (see here) This post addresses another exception to the overtime rule the exemption for employees of a seasonal amusement or recreational establishment

The Exemption for Employees of Seasonal Recreational Establishments

Some seasonal employees are not entitled to overtime pay even if we would normally think of their work as being nonexempt Section 213(a)(3) of the Fair Labor Standards Act provides that the overtime rule shall not apply to

any employee employed by an establishment which is an amusement or recreational establishment organized camp or religious or non-profit educational conference center if

(A) it does not operate for more than seven months in any calendar year or

(B) during the preceding calendar year its average receipts for any six months of such year were not more than 3313 per centum of its average receipts for the other six months of such year

The Meaning of ldquoEstablishmentrdquo

For a position to qualify for the seasonal employee exemption its duties must be performed at a facility that it is a distinct physical place of operations that is separate from the main administrative location of the organization See 29 CFR sect 77923 As the US Department of Labor explains in an opinion letter

A city or townrsquos entire municipal government for example cannot qualify as an amusement or recreational establishment Likewise parks department employees who are employed by a central non-recreational agency facility do not qualify for the exemption even if they are employed only seasonally

The letter lisst a number of examples of public-sector facilities that may qualify as separate establishments

beachesgolf coursesswimming pools

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Coates CanonsNC Local Government Lawhttpcanonssoguncedu

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boardwalksstadiumssummer campsice-skating rinks andzoos

Other venues that may qualify as separate establishments may include nature centers tennis courts fairgrounds and museums

The Meaning of ldquoSeasonalrdquo

To be a ldquoseasonalrdquo establishment the facility must be one that operated for no more than seven months in any calendar year Public employers who consult the US Department of Labor regulation implementing this section of the FLSA ndash 29 CFR sect 779385 ndash may notice that there is another way that a facility may qualify as seasonal namely if ldquoduring the preceding calendar year its average receipts for any 6 months of the year were not more than 33 percentum of its average receipts for the other 6 months of such yearrdquo The average receipts provision does not apply to government establishments whose operating costs are met wholly or primarily from general tax revenues See US Department of Labor Wage and Hour Division Opinion Letter 2009-5 (January 14 2009)

Year-Round Employees Spending Part Year at the Seasonal Establishment

Year-round employees who spend part of the year working at a seasonal recreational establishment and the other part of the year working for the city or countyrsquos year-round operations are exempt for overtime for those duties performed at the seasonal establishment but must be paid overtime during that part of the year that they are working at the main facility

Employees Who Take a Second Job at the Seasonal Establishment

Some year-round employees may take a second job at city or countyrsquos seasonal recreational establishment Under these circumstances the exemption from overtime for employees at a seasonal establishment will not apply Why not Because the FLSA regulations require all hours worked by a nonexempt employee for the same employer count toward assessing the employeersquos right to overtime in a given workweek This is true even where the employee is working two unrelated jobs

Conclusion

Governments who operate truly separate and seasonal establishments ndash pools beaches camps recreational facilities and the like ndash may employ seasonal workers without paying them overtime for hours worked over 40 in a week

Links

wwwlawcornelleduuscodetext29213wwwlawcornelleducfrtext2977923wwwdolgovwhdopinionFLSA20092009_01_14_05_FLSApdfwwwlawcornelleducfrtext29779385

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Coates Canons Blog Paying Employees Who Are Absent in Inclement Weather

By Diane Juffras

This entry was posted on November 20 2013 and is filed under Compensation amp Benefits Employment Fair Labor Standards Act

Itrsquos that time of year Winter storms may make it impossible for local government employees to make it to work Sometimes absences are for only a day or two and once the roads are clear and it is safe to drive employees return to work At other times storms cause power outages that may last for a week or longer forcing employees and their families to relocate temporarily and closing schools and daycare centers and sometimes even the government workplace itself Some local government employees may be able to work remotely For others remote work will be impossible as they must be physically present at the workplace to engage in their job duties Under the Fair Labor Standards Act what happens to wages and salaries when employees cannot work The rules may briefly be summarized thus

Nonexempt employees do not have to be paidExempt employees do not have to be paid if they do not work for an entire workweek Where the workplace remains open exempt employees who work for less than a full work week may be required to use accrued paid leave for the time that they are absent If they do not have accrued paid leave then a public employer may count this as an absence for personal reasons and deduct the time lost from their salary on a pro-rata basis If conditions require an employer to close its workplace or any part of the workplace for less than a full workweek it must pay its exempt employees their full weekly salary although the employer may require employees to apply as much accrued paid leave as an employee has available

As a quick refresher remember that nonexempt employees are entitled to overtime pay once they have worked more than 40 hours in a workweek and exempt employees (who must be paid the same salary without regard to the number of hours they work) are not entitled to overtime pay

Nonexempt Employees

For nonexempt employees a simple rule applies in all circumstances the FLSA requires employers to pay nonexempt employees only for the hours that they have physically worked If at any given time there is no work for an employee to perform or if the employer decides to close on what would otherwise be a workday a nonexempt employee is not entitled to any compensation Most public employers however offer some mix of paid sick and vacation leave to their employees both nonexempt and exempt In order to alleviate the hardship that comes from not being paid an expected wage employers may allow nonexempt employees to draw on their accrued paid leave including accrued comp time in order to turn unexpected days off caused by inclement weather into paid time

This is true both for nonexempt employees paid on an hourly basis and nonexempt employees paid on a salary basis When nonexempt salaried employees are paid on a salary basis it is as a matter of convenience in contrast to FLSA-exempt positions which must be paid on a salary basis (see my previous blog post on what it means to be paid on a salaried basis here) As with nonexempt employees paid on an hourly basis salaried nonexempt employees must record the time that they have worked on a daily basis and must be paid overtime for any hours that they physically work in excess of 40 The same rules apply to all nonexempt employees The rules for exempt employees are different

Exempt Employees

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The general rule under the FLSA is that employers who make unlawful deductions from the salaries of their exempt employees lose the exemption and convert those employees into nonexempt employees entitled to overtime That is why employers must be careful during periods of inclement weather to follow the FLSA regulations that provide for exceptions to this rule There is no general weather-related exemption but certain other rules allow local government employers to minimize the financial impact of the days employees miss due to bad weather on their unitrsquos budget and operations

Absent from Work for a Full Week or More or Workplace Closed for a Full Week or More

The FLSA requires employers to pay exempt employees their full salary for any week in which they have performed any work For example if an exempt employee works on Monday but performs no other work on any other day of the week the employer must still pay the employee his or her full weekly salary But where an exempt employee performs no work whatsoever in a given workweek the employer need not pay the employee at all (See here for 29 CFR sect 541602 for the general rule subsection (b) explains the exceptions) This is true regardless of whether the employee does not work for that full week because of illness because of traffic or weather conditions or because the employer tells the employee not to come into work An employer may allow employees to draw upon accrued paid leave during an absence of a full week

Absent from Work for Less than a Full Workweek While the Workplace is Open

Under normal circumstances employers require exempt employees who are absent for one or more days mdash full days or part days mdash to use accrued paid sick vacation or personal leave to cover the absence This is permissible under the FLSA because paid leave is an employer-created benefit not subject to the FLSA When an employer pays its exempt employees their stated salary and deducts the equivalent amount of leave from their accrued leave bank the employer satisfies the FLSA without compensating the employee for time during which no work was performed and thus without incurring unbudgeted salary expenses (the cost of the paid leave having already been taken into account in the employerrsquos budget) The US Department of Labor has addressed this issue several times in formal Opinion Letters issued by the Administrator of the Wage and Hour Division explaining in one that

Employers can make deductions for absences from an exempt employeersquos leave bank in hourly increments so long as the employeersquos salary is not reduced If exempt employees receive their full predetermined salary deductions from a leave bank whether in full day increments or not do not affect their exempt status (emphasis added)

Sometimes however an employee does not have any accrued leave upon which to draw The general rule requiring exempt employees to be paid their full salary for any week in which they perform any work would suggest that an employer would have to pay exempt employees their full salary if they were absent for a day or two for bad weatherand had no accrued leave In both the public and private sectors however deductions from the salary of an exempt employee are allowed where the employee is absent for one or more full days for personal reasons other than sickness What are personal reasons other than sickness Just about anything During inclement weather personal reasons are most likely to be

problems in getting to work either because the roads are dangerous or impassable or because public transportation is shut down or curtailedsick dependents needing care such as the employeersquos children or elderly parentschild care issues where the regular day care provider is not operating ordamage to or loss of the employeersquos home

Where an employee is absent for personal reasons for one or more full days and part of another day the rules governing the public and private sectors diverge In the private sector an employer may deduct from an employeersquos salary for absences for personal reasons only in full-day increments It may not deduct any partial-day absences from the employeersquos salary A public sector employer on the other hand may deduct partial-day absences for personal reasons from an exempt employeersquos salary when they have no accrued paid leave just as it may deduct partial-day absences due to illness from an employeersquos salary when the employee has no accrued sick leave available The public sector exception is set forth at 29 CFR sect 541710

(a) An employee of a public agency who otherwise meets the salary basis requirements of sect 541602 shall not be disqualified from exemption on the basis that such employee is paid according to a pay system established by statute ordinance or regulation or by a policy or practice established pursuant to principles of public accountability

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under which the employee accrues personal leave and sick leave and which requires the public agency employeersquos pay to be reduced or such employee to be placed on leave without pay for absences for personal reasons or because of illness or injury of less than one work-day when accrued leave is not used by an employee because

(1) Permission for its use has not been sought or has been sought and denied

(2) Accrued leave has been exhausted or

(3) The employee chooses to use leave without pay

Note that in subsection (a)(1) the regulation allows public employers to deduct both full and partial day absences from the pay of exempt employees where accrued paid leave is available but the employee has asked for and the employer has denied the employee permission to use it and the employee is absent anyway This situation is likely to arise in an emergency where the manager or department head has designated certain employees as ldquoessential personnelrdquo and ordered them to report to work at the same time that other ldquononessentialrdquo employees are ordered or given permission to stay home If an employee who has been deemed essential refuses to report for duty a public employer may deduct their salary not only in full day increments as in the private sector but in partial-day increments as well even if they have accrued leave available for use (of course the employer may also fire the employee for insubordination)

Workplace Closed for Less than a Full Work Week

When inclement weather forces an employer to close its workplace for less than a full work week the employer must pay exempt employees their full weekly salaries The regulation defining salary basis is explicit on this point

An employee is not paid on a salary basis if deductions from the employeersquos predetermined compensation are made for absences occasioned by the employer or by the operating requirements of the business If the employee is ready willing and able to work deductions may not be made for time when work is not available

For a DOL Wage and Hour Opinion Letter on this issue see here

It is likely that any condition that forces a public employer to close its workplace to all but essential personnel would keep nonessential employees at home anyhow ndash that is to say that employees are not going to be ldquoready willing and able to workrdquo An employer might object perhaps not unreasonably that it should not have to compensate employees who would not come to work if it stayed open The presumption behind the regulation however is that employees are ready willing and able to work when the employer is open When the employer closes down exempt employees must be compensated

Employers may however apply any accrued paid leave that an exempt employee has to the days during which the employer is shut down

an employer can substitute or reduce an exempt employeersquos accrued leave for the time an employee is absent from work even if it is less than a full day and even if the absence is directed by the employer without affecting the salary basis of payment provided that the employee still receives in payment an amount equal to the employeersquos guaranteed salary

But where the employee has no accrued paid leave to apply the employer must pay the employee his or her full salary ndash a situation that a public employer should try to avoid

If an employer requires that an exempt employee work less than a full workweek the employer must pay the employeersquos full salary even if (1) the employer does not have a bona-fide benefits plan (2) the employee has no accrued benefits in the leave bank (3) the employee has limited accrued leave benefits and reducing that accrued leave will result in a negative balance or (4) the employee already has a negative balance in the accrued leave bank

(See also DOL Wage and Hour Opinion Letter 2005-41)

As we approach the winter storm season local government employers should review their inclement weather policies to make sure they comply with the FLSA

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Links

wwwlawcornelleducfrtext29541602wwwdolgovwhdopinionFLSA20092009_01_16_18_FLSApdfwwwlawcornelleducfrtext29541710wwwdolgovwhdopinionFLSA20092009_01_14_02_FLSApdfwwwdolgovwhdopinionFLSA20052005_10_24_41_FLSApdf

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Coates Canons Blog Is Training Time ldquoWorkrdquo That Must Be Paid

By Diane Juffras

This entry was posted on February 26 2016 and is filed under Compensation amp Benefits Employment Fair Labor Standards Act General Local Government (Miscellaneous)

Amanda works in the information technology department of Paradise County government She is nonexempt under the Fair Labor Standards Act meaning that she is entitled to overtime premium pay for hours worked over 40 in a week But she is entitled to pay only for hours she actually works Amanda has been accepted to the School of Governmentrsquos Municipal and County Administration course She is excited to get a chance to understand the larger responsibilities and workings of local government which will better enable her to design and code programs for the countyrsquos very different departments She is a little less excited when her department head tells her that she will not be paid for the time she spends in class ldquoThat canrsquot be rightrdquo she thinks ldquoAfter all the class time all takes place during regular working hours and Irsquom attending the class as an employee of Paradise Countyrdquo Under the Fair Labor Standards Act (FLSA) is the time Amanda spends in the Municipal and County Administration course ldquoworkrdquo for which she must be paid

Yes The time Amanda spends attending the Municipal and County Administration course is compensable Her situation satisfies the FLSArsquos standards for compensable training time the training will take place during regular working hours and it is directly related to her job

Background

The FLSA requires employers to pay employees time-and-one-half their regular rate of pay for all hours over 40 that employees work in a given week unless an employee is exempt under the FLSArsquos salary basis test (see here) and one of either the executive administrative or professional duties tests (On the duties tests see here here here here and here) Exempt employees must be paid the same salary even if they work fewer than 40 hours and they are not entitled to overtime pay when they work more than 40 hours

When exempt employees attend continuing education or training courses they continue to receive their regular salary neither more nor less whether the class is held during or after regular working hours But because nonexempt employees are paid only for the hours they actually work whether during or outside of regularly scheduled hours the question necessarily arises must nonexempt employees be paid for the time they are in classes and other forms of training and does that time count toward overtime Is the training time ldquoworkrdquo

The General Rule

Under the FLSA time employees spend on job-related training activities is generally compensable The general rule is that employees do not have to be compensated for training time if

1 attendance is outside the employeersquos regular working hours2 attendance is voluntary3 the course is not directly related to the employeersquos job and4 the employee does not perform any productive work during time in attendance at the course

Time spent on training and similar activities must satisfy all four requirements for it to be treated as not compensable (keep in mind however that an employer may choose to pay nonexempt employees for their training time even if under the FLSA they do not have to do so because these four conditions are satisfied) Letrsquos take a closer look at these requirements

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Outside Regular Working Hours

The requirement that attendance at the training be outside of an employeersquos regular working hours to be noncompensable is fairly straightforward For Amanda it is clear that her participation in the Municipal and County Administration course will be compensable to the extent that class time is all scheduled within the hours she regularly works Should class time spill over into what would normally be Amandarsquos nonworking hours the other three factors would have to be considered to determine whether those hours are compensable

Voluntary Attendance

The FLSA regulations expressly state here that attendance is not voluntary if the employer requires the employee to take the class It is also not voluntary if employees are led to believe that their present working conditions or their continued employment would be adversely affected by not attending the class

Herersquos a tricky situation Is training time voluntary when employees undertake the training outside of regular working hours in order to pass a test that is required by the employer This question frequently arises in the context of public safety where law enforcement officers firefighters and sometimes paramedics and EMTs are required to pass a physical abilities test In cases such as these the training time would be compensable if the employer required its employees to take a particular fitness class outside of work or to follow a specific training regimen in preparation for the test But where employees are not required to spend a specific amount of time training for the test or do specific exercises or activities the training time is not compensable This is true even where it would be quite difficult to pass the test without training or preparation For cases with extended discussions of this issue see here and here

Training Not Directly Related to the Employeersquos Job

Whenever training is directly related to an employeersquos job it is compensable The FLSA regulations explain that training is directly related to the employeersquos job if it is designed to make the employee handle his or her job more effectively Training whose purpose is to prepare an employee for another job or to teach an employee a new or additional skill is not considered directly related to the employeersquos job As the regulations explain

Where a training course is instituted for the bona fide purpose of preparing for advancement through upgrading the employee to a higher skill and is not intended to make the employee more efficient in his present job the training is not considered directly related to the employeersquos job even though the course incidentally improves his skill in doing his regular work

This requirement has been the basis of no small amount of litigation One court held that any training that does not apply to a specific job but only to better performance in the workplace in general is not work directly related to an employeersquos job In that case an employer required its operating engineers who were not required to have college degrees to pass a series of foundational skills assessments Elsewhere the federal Eleventh Circuit Court of Appeals found that off-duty fitness training undertaken by police officers in order to pass a required physical fitness test provided health benefits that extended beyond their employment and was not directly related to their job In an earlier case the Eleventh Circuit had found that training that related to work that represented only ten percent of an employeersquos job duties was not directly related to his job Finally the US Department of Labor itself said in an opinion letter that where a job did not require proficiency in English an employeersquos study of employer-provided written instruction in English outside working hours was not directly related to the employeersquos job DOL agreed with the employer that while such instruction might enhance the employeesrsquo job satisfaction improve morale at work and provide the employees with greater opportunities in the outside workplace it did not help the employee perform his job more efficiently The fact that the training may have had an indirect effect on an employeersquos current job (as one might assume greater facility in English would have) did not make it directly related to the job

Training That Is a Precondition of Employment

What if training of a certain kind is a precondition of employment but the employer will allow applicants to complete the training on their own time after they have begun work In one case Chao v Tradesmen International Inc the federal Sixth Circuit Court of Appeals found that such time was not compensable The employer Tradesmen International was a

Page

skilled tradesmen leasing company that required all field employees to have completed a 10-hour OSHA general construction safety course It allowed applicants to complete the training post-hire after regular working hours with the understanding that Tradesmen would terminate their employment if they did not register for the training course within sixty days of hire and complete it within a reasonable amount of time afterwards

The court in this case did not analyze the situation under the training time regulation we have considered so far Instead it looked at the provisions of the Portal-to-Portal Act an amendment to the FLSA that requires employers to compensate employees for activities that may occur before or after the workday proper but are nonetheless an integral and indispensable part of the principal activities for which they are employed The court found that the safety course although required by the employer was not an integral and indispensable part of the tradesmenrsquos duties See here for a case where the court found that the time spent by members of private campus police force in EMT training which was a precondition to their hiring was not an integral and indispensable part of their job duties

A Special Rule Applicable to Government Employers Only

The FLSA regulations here as elsewhere make a concession to the ways in which public-sector employment sometimes differs from private-sector employment In 29 CFR sect 553226 the DOL identifies as noncompensable time any time a state or local government employees spends outside of working hours in a class or training session that is required for certification of persons performing their jobs Thus the training that the state of North Carolina requires for certification and recertification of paramedics and EMTs is not compensable time This is true even if the local government employer is paying for the cost of the training (again the employer is not forbidden from treating the training time as compensable work it just does not have to do so under the FLSA)

Similarly when a local law enforcement officer is attending class at a law enforcement training facility or a firefighter is attending a fire academy the hours not spent in class are not compensable even where the participants are residing on-campus for the period of the training program Although employees are not ldquohomerdquo and are not free to pursue their usual off-duty activities while at the training site they may still use the hours not spent in class for their own purposes reading sleeping surfing the internet or watching TV If Amanda in the opening hypothetical is not returning home each night but is staying in a hotel in Chapel Hill for each night during the Municipal and County Administration course her time outside of class is not compensable even though she is not home Of course if she performs work that she would otherwise be doing back in her office in Paradise County in her hotel room at night the time she spends on that work would be compensable

Note that an employer that takes advantage of this special local government exception does not have to satisfy the general rules for compensating training time discussed above

When Employees Enroll in Classes or Training at Their Own Initiative

The FLSA regulations also address both training that employees enroll in of their own accord and special employer-offered courses of which employees may voluntarily take advantage When an employee enrolls in a course or college program after working hours at his or her own initiative the time is not compensable even if the coursework is directly related to the employeersquos job Occasionally an employer will offer a free class or training opportunity after working hours for the benefit of its employees If attendance is not required and the employeersquos participation is voluntary the time spent in such classes would not be considered hour worked For the regulations see here and here

Links

wwwlawcornelleducfrtext2978527wwwlawcornelleducfrtext2978528caselawfindlawcomus-11th-circuit1233486htmlwwwuscfcuscourtsgovsitesdefaultfilesopinionsHEWITTBull2pdfwwwlawcornelleducfrtext2978529casetextcomcasemaynor-v-dow-chemical-co-2lawjustiacomcasesfederalappellate-courtsF2806155145578wwwdolgovwhdopinionFLSA20062006_03_03_05_FLSApdf

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casetextcomcasechao-v-tradesmen-intern-inclawjustiacomcasesfederalappellate-courtsF3285138570112wwwlawcornelleducfrtext29553226wwwlawcornelleducfrtext2978530wwwlawcornelleducfrtext2978531

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Coates Canons Blog Must Travel Time to Training and Conferences Be Paid

By Diane Juffras

Article httpcanonssoguncedumust-travel-time-training-conferences-paid

This entry was posted on July 25 2016 and is filed under Compensation amp Benefits Employment Fair Labor Standards Act General Local Government (Miscellaneous)

In a previous blog post I explained the Fair Labor Standards Act rules that govern paying for nonexempt employees for training time Much of an employeersquos training of course is done on-site But what happens when an employee travels to attend a training or a conference Is the time spent driving to the training event compensable Does it matter whether the employee is the driver or is a passenger in a vehicle driven by another You bet it does The rules governing the compensability of travel time are among the most confusing that the US Department of Labor has issued under the FLSA

This blog post is not about exempt employees When exempt employees travel to another location for a conference or training program whether that travel is near or far doesnrsquot affect compensation Exempt employees are paid the same amount each week regardless of how many hours they work So if they work their regular schedule during the workweek but spend three hours Friday evening driving to the site of a conference that takes place on Saturday their compensation is unaffected

Nonexempt employees however are generally paid by the hour or are paid on the basis of a regular hourly rate and must be paid time-and-one-half premium overtime pay for every hour over 40 in a workweek So if s nonexempt employee works her regular schedule during the workweek but spends three hours Friday evening driving to the site of a conference that takes place on Saturday she will be paid more than she is usually paid for a regular workweek because she has worked more

Travel Time Rules

There are four basic rules governing whether time spent traveling for work must be compensated They are

1 Travel away from home must be paid when it occurs during the employeersquos regularly scheduled hours2 Travel away from home must be paid when it occurs during what would be working hours but on nonworking days3 Time traveling away from home outside of regular working hours as a passenger on in a car or on an airplane train

or bus does not have to be paid4 Time traveling away from home outside of regular working hours as the driver of an automobile must be paid

Letrsquos examine these rules

Travel Away from Home during an Employeersquos Workday

Travel away from home or from the employeersquos worksite is compensable when it takes place during an employeersquos regularly scheduled hours of work The easiest way to think about this is to remember that here the employee is simply substituting travel for other duties It doesnrsquot matter whether the employee is traveling from worksite to worksite as a building inspector might do or to a meeting across town or across the country The employee is entitled to be paid for the time See 29 CFR sect 78539

Travel during a Non-Workday

The rules governing travel away from home or from the employeersquos worksite on a non-workday are less intuitive than the rule that applies to travel during the workday because it makes a distinction between travel that occurs during the hours that employee would be scheduled to work if it were a workday and the hours that an employee would be off-duty if it were

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a regular workday

Imagine that Phil and Patti both nonexempt employees drive from Paradise NC to Chapel Hill on late Sunday afternoon They are attending a class in public employment law at the School of Government and need to be there by 9 am Since it is a good five-hour drive from Paradise to Chapel Hill they need to leave the day before They set out at 3 pm Patti drives Phil sits in the passenger seat and sings along to the radio to entertain Patti

Patti and Philrsquos regular hours are Monday to Friday 9 am to 5 pm 29 CFR sect 78539 directs that Phil be paid for two hours of work on that Sunday from 3 pm to 5 pm His employer does not have to pay him for the additional three hours he spends in the car from 5 pm to 8 pm Patti on the other hand gets paid for the entire trip from 3 pm to 8 pm

Why the difference

To start with 29 CFR sect 78539 provides that travel away from home is compensable when it occurs during what would be working hours on a nonworking day In other words if an employee regularly works from 9 am to 5 pm from Monday through Friday travel time on from 9 am to 5 pm on Saturday and Sunday is also compensable time So both Phil who is the passenger and Patti who is the driver are paid for the hours between 3 pm and 5 pm

Different Rules for Passengers and Drivers Who Travel Outside of Regular Work Hours

Different rules apply to the roles of driver and passenger 29 CFR sect 78541 provides that anyone driving is working while traveling But 29 CFR sect 78539 makes clear that the US Department of Labor which enforces the FLSA and issues the FLSA regulations will not ldquoconsider as worktime that time spent in travel away from home outside of regular working hours as a passenger on an airplane train boat bus or automobilerdquo This is why Patti is paid for the hours from 5 pm to 8 pm and Phil is not Had more of their trip taken place between the hours of 9 am to 5 pm Philrsquos would have been paid more for the trip

Working on an Employer Project While Passenger in an Automobile

What if Phil owed the city manager a report first thing when he returns from Chapel Hill and instead of regaling Patti during the ride works on his report on his laptop during the entire ride In that case Phil would be paid for the entire trip ndash from 3 pm to 8 pm ndash because he was performing work for the employerrsquos benefit during that time It isnrsquot any different than if Phil were sitting on his couch at home working on the report The time would be compensable Any time a nonexempt employee performs work at the direction of and for the benefit of the employer the time must be paid whether on-site or at home whether in town or traveling See 29 CFR sect 7857 and 29 CFR sect 78511

Links

wwwgpogovfdsyspkgCFR-2011-title29-vol3xmlCFR-2011-title29-vol3-sec785-39xmlwwwgpogovfdsyspkgCFR-2011-title29-vol3xmlCFR-2011-title29-vol3-sec785-41xmlwwwgpogovfdsyspkgCFR-2011-title29-vol3xmlCFR-2011-title29-vol3-sec785-7xmlwwwgpogovfdsyspkgCFR-2011-title29-vol3xmlCFR-2011-title29-vol3-sec785-11xml

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Coates Canons Blog Permissible Deductions from the Salaries of Exempt Employees

By Diane Juffras

This entry was posted on October 08 2014 and is filed under Compensation amp Benefits Employment Fair Labor Standards Act General Local Government (Miscellaneous)

The federal Fair Labor Standards Act permits employers to exempt employees from the lawrsquos overtime requirements if their job duties meet one of three duties tests (discussed previously here here here here and here) and crucially if they are paid on a salary basis (discussed previously here) What happens if an employer makes deductions from the salary of an exempt employee As a general rule deductions violate the salary basis test and destroy the exemption making the employee eligible for overtime This rule does have exceptions This blog post discusses four circumstances in which the FLSA allows public employers to make deductions from the salary of an exempt employee without destroying the exemption

1 Deductions for Absences in Excess of Accrued Sick or Vacation Leave This is probably the most frequently used of the permissible exceptions to the rule prohibiting deductions from the pay of an exempt employee The exception may be used only by public employers and only if they have adopted a policy crediting employees with paid sick vacation or personal leave and requiring that an employeersquos pay be docked when an employee is absent for personal reasons or because of sickness or injury and has no accrued paid leave available The deduction from salary may be taken in full-day increments or on a pro rata basis for less than a full day

A public employer may also apply this exception when an employee does not bother to ask for permission to take time off or when the employee asks for permission to take leave it is denied and the employee takes time off anyway The exception also applies when an employee has accrued paid leave but asks to be put on unpaid leave and the employer agrees

The regulation authorizing this most useful exception may be found here Note that the regulation also authorizes employers to furlough exempt employees by temporarily categorizing them as nonexempt (and thus requires them to pay these employees for any overtime worked) in workweeks during which the jurisdiction wishes to furlough its employees for budgetary reasons

2 Deductions for Full-Day Disciplinary Suspensions for Exempt Employees Under this second exception an exempt employee who violates a generally applicable rule of workplace conduct may be placed on an unpaid disciplinary suspension but only in increments of a full-day In other words the employer may dock the employeersquos salary in increments of one day two days three days etc It may not dock the employeersquos salary for the equivalent of two-and-one-half days of work for example

The workplace misconduct must be a violation of a rule that is written and that applies to all employees As was the case with the excess leave exception discussed above an employer must have a written policy in place before it can use the unpaid disciplinary suspension exception This exception is found at 29 CFR sect 541602(b)(5)

The regulation does not define the term ldquoworkplace conductrdquo It gives two examples however The first is of a violation of the employerrsquos sexual harassment policy and the second is of a violation of a policy prohibiting workplace violence Both examples involve serious misconduct with the potential for employer liability for damages suffered by other employees In the Preamble Discussion that accompanied the publication of the rule in the Federal Register the US Department of Labor gave two additional examples mdash a violation of an employerrsquos written drug or alcohol policy or a violation of the employerrsquos written policy concerning off-duty conduct or violations of law See 69 Fed Reg 22177 for this discussion

Given these examples discretion would say that employers should not place exempt employees on an unpaid disciplinary

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suspension for insubordination excessive tardiness or for the vague offense of ldquoconduct unbecoming a government employeerdquo

3 Docking an Exempt Employeersquos Pay for Safety Violations The FLSA regulations have long included a provision allowing employers to dock an exempt employeersquos pay as a penalty for violation of a safety rule of major significance This exception is poorly understood and North Carolina public employers have not made much use of it

This exception is found at 29 CFR sect 541602(b)(4) The rule explains that ldquo[s]afety rules of major significance include those relating to the prevention of serious danger in the workplace or to other employees such as rules prohibiting smoking in explosive plants oil refineries and coal minesrdquo The relatively few cases in which this regulation is at issue demonstrate that this is a rule intended to prevent serious danger to the workplace or other employees The exemption does not appear to cover violation of safety rules designed to prevent danger to the general public

So for example a law enforcement officerrsquos failure to remain at his assigned post sleeping while or duty or failing to report the loss of his service weapon have been found to put fellow officers at risk and thus to be violations of safety rules of major significance A police officerrsquos failure to respond to a traffic accident has been found to jeopardize EMTs working at the scene and to be a violation of a major safety rule A fire truckrsquos failure to respond to the correct address was found to be a violation of a safety rule of major significance because the delay in its arrival at the scene endangered fellow firefighters already at the scene

In contrast law enforcement officers did not violate a safety rule when they accepted free sausage sandwiches from a merchant nor did an employee who failed to report absences from work A fire captainrsquos failure to prevent subordinates from downloading pictures of nude women from the internet was also not a violation of a safety rule of major significance

The regulation provides that a deduction for a violation of a safety rule of major significance may be made in any amount and need not be tied to the employeersquos salary rate Thus this rule may be used to fine exempt employees as well as to suspend them

4 Deductions for Partial First or Last Week of Work or for Partial Week FMLA Leave An exempt employeersquos first or last week of work may not be a full workweek The FLSA allows an employer to pay a proportionate part of an exempt employeersquos full salary for the time actually worked in the first and last week of employment This exception is found in subsection (b)(6) of 29 CFR sect 541602 Similarly an employee may begin or end a block of unpaid Family and Medical Leave Act leave midweek or may take intermittent FMLA leave ndash blocks of time amounting to less than a full workweek because of the flare-up of chronic conditions or for scheduled medical treatments Subsection (b)(7) allows employers to pay a proportionate part of an exempt employeersquos full salary for the time actually worked in a week in which FMLA leave has been used

Links

wwwlawcornelleducfrtext29541710wwwlawcornelleducfrtext29541602wwwgpogovfdsyspkgFR-2004-04-23pdf04-9016pdf

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Coates Canons Blog May an Employee Work a Second Job for the Same Employer

By Diane Juffras

Toby works for the City of Paradise NC in a full-time 40 hours-per-week nonexempt position in the finance department He gets the opportunity to work a second 17 hours-per-week part-time nonexempt job for the Paradise information technology department in the evenings Does the city have to pay Toby overtime premium pay for the hours he works in the second job

Yes Even though Toby would be happy to make an extra $15 per hour straight time in the second job and would take the job without the overtime pay the city must pay overtime premium pay

Background

Under the Fair Labor Standards Act (FLSA) employers have two kinds of employees exempt and nonexempt Exempt employees are those who satisfy the FLSArsquos salary basis test and either the executive administrative or professional duties test Exempt employees need not be paid overtime if they work in excess of 40 hours in a week Everyone else is considered nonexempt and must be paid time-and-one-half premium pay for hours over 40 For how to determine whether an employee is exempt or nonexempt see here here here here here and here

Second Unrelated Job for the Same Employer

Tobyrsquos situation is not unusual Many employees want to supplement their earnings Having a second unrelated job with the same local government that employs them full-time can be very convenient Local government employers are happy to give their employees a chance to earn more money and to avoid the hassles of advertising and interviewing for a position that is less than full-time and the hazards of hiring someone unknown who may turn out to be a lousy employee

But this mutually-desired situation is sometimes sidetracked by the employerrsquos realization that if the employee is nonexempt and is eligible for overtime compensation in his first job then the hours the employee works in the second unrelated position will count toward overtime For the purposes of the FLSA all hours worked by a nonexempt employee for the same employer count toward assessing the employeersquos right to overtime in a given workweek This is true even where the employeersquos primary and secondary jobs are in two different departments as the US Department of Laborrsquos FLSA regulations make clear

If in any workweek an employee is covered by the [Fair Labor Standards] Act and is not exempt from its overtime pay requirements the employer must total all the hours worked by the employee for him in that workweek (even though two or more unrelated job assignments may have been performed) and pay overtime compensation for each hour worked in excess of the maximum hours applicable

Nonexempt Employee with Second Nonexempt Job

In Tobyrsquos situation overtime pay is required But his employer has two options for calculating the overtime pay Where a nonexempt employee performs two or more different kinds of work for two different hourly rates the regulations allow the employer and employee to agree in advance that the employee will be paid time-and-one-half of the bona fide regular rate of the job that is performed during the overtime hours In the absence of such an agreement the employeersquos regular rate for that week is the weighted average of both rates This means in the words of the regulations that ldquohis total earnings (except statutory exclusions) are computed to include his compensation during the workweek from all such rates and are

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then divided by the total number of hours worked at all jobsrdquo

Nonexempt Employee with Second Exempt Job

Where a nonexempt employee takes a second job that is exempt the employee must be compensated at a time-and-one-half overtime rate for any hours worked over 40 The situation is treated as if the second position was nonexempt rather than exempt

Exempt Employee with a Second Nonexempt Job

Where an exempt employee takes a second job that is nonexempt the hours worked at the second job are paid at the regular straight-time rate for that job If the employee begins to spend as much or more time in second nonexempt job as he or she does in the original exempt position the situation may turn in to one of a nonexempt employee with a second exempt job

Exempt Employee with a Second Exempt Job

Where an exempt employee takes a second job that is also exempt the employee will earn two separate salaries without any additional compensation regardless of how much time the employee spends in either position

Whose Budget Pays the Overtime

This is usually where things fall apart Neither the department where the first job is located nor the department hiring the employee for a second job has a problem with the other department paying the extra half-time premium portion of the employeersquos wages The first department is understandably unwilling to pay the overtime premium for work that doesnrsquot benefit it The second department will be paying straight-time if it hires an outsider for the part-time position so its budget will bear the responsibility for the straight-time hours of the employeersquos second job But the second department doesnrsquot want to cover the extra half-time premium pay because from its perspective if it werenrsquot for the employeersquos work for the first department there would be no need to pay overtime

This isnrsquot really a legal issue Whose budget the money comes from or whether this employee can be hired into a second job at all is a decision for the city or county manager

Can Employees Waive Their Rights to Overtime

Suppose Toby is willing to work the second job at a straight-time rate and to waive his right to do so After all if he worked a second job for a different employer he would only get straight-time Toby would just as soon work for the same local government employer Can he waive his right to overtime

The answer to that question is a well-established and resounding ldquoNOrdquo As long ago as 1945 the US Supreme Court held that employers and employees could not agree to terms of payment that violate the FLSA That foundational principle has been reaffirmed in the years since See here and here to read the Supreme Court cases

The Occasional and Sporadic Second Job

There is a single small exception to the second job rule When a local government employee works a second unrelated job for the same employer on a part-time basis but only occasionally or sporadically the hours worked in the second job do not have to be counted for the purpose of overtime but may be paid at a straight time rate For the purposes of this exception the terms ldquooccasionalrdquo and ldquosporadicrdquo mean infrequent irregular or occurring in scattered instances The work may be recurring (an event held every fall or every holiday season) but it cannot be regular (weekly or monthly according to a regular schedule) Examples of occasional and sporadic part-time work include

taking tickets or providing security for special events such as concerts team sporting events or lectures at stadiums or auditoriumsofficiating at special youth or sports events at public recreation and park facilitiesassisting in food or beverage sales at concerts sports events or special events such as a county fair

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But if an employee does such work over and over again however the job will lose its occasional and sporadic status and be subject to overtime as a second job with the same employer

Note that to exclude such hours from overtime the occasional or sporadic work may not be within the same general occupational category as the employeersquos regular work Examples of occasional and sporadic activities that are in a different capacity from an employeersquos regular work include

an employee of the finance department occasionally refereeing for an adult evening basketball league sponsored by the parks and recreation departmenta bus driver assisting in crowd control at a winter festival

an administrative assistant substituting as a coach for a youth basketball teama maintenance engineer providing instruction on auto repair as part of a single-day parks and recreation program

Examples of occasional and sporadic activities that would not be considered in a different capacity from an employeersquos regular work include

a parks and recreation employee primarily engaged in playground maintenance who also from time to time cleans an evening recreation centerpublic safety employees taking on any kind of security or safety function within the same local government ndash such

assignments are never considered to be employed in a different capacity

Finally the occasional and sporadic work may not be excluded from overtime payment if the employer orders or in any way pressures employees to undertake the work The decision to work the occasional and sporadic assignment must be made freely The complete regulation may be found here

Links

wwwlawcornelleducfrtext29778103wwwlawcornelleducfrtext29778419wwwlawcornelleducfrtext29778115caselawfindlawcomus-supreme-court324697htmlcaselawfindlawcomus-supreme-court450728htmlwwwlawcornelleducfrtext2955330

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

Coates Canons Blog The Final New Overtime Rule is Finally Here

By Diane Juffras

Article httpcanonssoguncedufinal-new-overtime-rule-finally

This entry was posted on May 25 2016 and is filed under Compensation amp Benefits Employment Fair Labor Standards Act General Local Government (Miscellaneous)

On May 18 2016 the US Department of Labor released the final rule raising the minimum salary an employee must make to be exempt from overtime and by that act making many more salaried employees eligible for overtime compensation The rule may be found here The changes to the old rule are few and not surprising as they closely track the proposed rule published last July The most significant change is as expected an increase in the amount an employer must pay for an employee to qualify for exempt status It increases from the current $455 per week to $913 per week ndash thatrsquos an increase of just over 100 from $23600 annually to $47476 annually The new salary minimum will be effective December 1 2016

Background

Under the Fair Labor Standards Act an employee is entitled to overtime premium pay of one-and-one-half times their regular rate of pay after working 40 hours in a week unless an exemption applies If an exemption applies the employee is said to be ldquoexemptrdquo and is not entitled to overtime pay no matter how many hours they work in a week An exemption applies if the employee is salaried and the position meets the requirements of the executive duties test the administrative duties test or the professional duties test

But even if the employee is salaried and the position satisfies one of the three duties tests the exemption does not apply if the employee is paid less than $455 per week or $23660 on an annualized basis Such a low-paid salaried employee is entitled to overtime pay after 40 hours

For an explanation of the salary basis test see here For discussion of the executive duties test see here the administrative duties test see here and here and the professional duties tests see here and here

Some History

March 2014 President Obama Calls for the Overtime Regulations to Be Updated

In March 2014 President Obama directed the US Secretary of Labor to modernize and simplify the federal Fair Labor Standards Act regulations The President was particularly concerned that the minimum required salary for exemption from overtime known as the salary threshold had not kept up with inflation In 1975 the salary threshold was $250 per week The next time the salary threshold was raised was in 2004 when it went to $455 per week There it has stayed since 2004 The President noted that in 2014 $455 per week was below the poverty line for a family of four and well below 1975 levels when adjusted for inflation In 2014 only 12 percent of salaried workers fell below the minimum salary threshold (the 12th percentile) ndash compared with 18 percent in 2004 and 65 percent in 1975 (the 18th and 65th

percentiles) The President did not tell DOL how to revise the regulations but it was clear that he wanted to bring more employees out of exempt status and to give them the benefits of overtime compensation And that is exactly what the new overtime regulations do

July 2015 DOL Issues Proposed New Overtime Regulations

The Department of Labor (DOL) issued proposed regulations in July 2015 suggesting a raise to the 40th percentile of full-time salaried workers ndash which was $921 per week or $47892 per year based on data from 2013 and expected to be $970 per week or $50440 per year in 2016 DOL also proposed that the minimum salary be automatically increased on an

Page

annual basis Finally DOL proposed a change in the minimum salary required for an employee to be exempt under the highly-compensated employee test from $100000 to $122148 annually DOL left open the possibility that it would revise one or more of the exempt duties tests in the final rule showing particular interest in limiting the amount of time an exempt employee could spend on nonexempt duties As required by the federal Administrative Procedures Act DOL asked for comments on its proposed rule The comment period closed in September 2015

The Final Rule

The final rule deviates from the proposed rule only in detail In a nutshell the final rule

raises the minimum salary necessary for an employee to be exempt from overtime from the current $455 per week ($23660 annually) to $913 per week ($47476 annually)raises the minimum salary necessary for an employee to be exempt from overtime as a highly-compensated employee from $100000 annually to $134004 annuallyprovides for automatic updating of the salary thresholds every three yearsallows employers to include nondiscretionary bonuses in an amount up to 10 of the minimum salary levelmakes no changes to the duties tests andmakes no changes to any of the other rules regarding compensable time and overtime

The final rule is effective December 1 2016

Minimum Salary Threshold of $913 Per Week

The new threshold of $913 per week represents the 40th percentile of earnings for a full-time (35 hours per week) full-year salaried worker in the fourth-quarter of 2015 In the preamble to the final rule DOL reiterated its conviction that a standard salary level at the 40th percentile will be a ldquobright linerdquo that adequately distinguishes between employees whose positions are likely to meet the duties test requirements and those whose positions are likely not to do so

DOL did make one change in response to comments it received A number of commenters expressed concern about the fairness of setting the minimum salary threshold based on a nationwide average The commenters believed that it unduly disadvantaged employers in a lower-wage region or a lower-wage industry The final salary threshold is therefore set at t

he 40th

percentile of earnings all full-time salaried workers in the lowest-wage census region which at this time is the South Census Region

The rule setting forth the new minimum salary threshold will be found at 29 CFR sect 541600 effective December 1 2016

New Inclusion of Nondiscretionary Bonuses in the Minimum Salary

One additional change will affect public employers who use longevity pay plans The new rule for the first time allows nondiscretionary bonuses and commissions to be included ndash to a limited extent ndash in the calculation of an employeersquos minimum salary In the final rule DOL limits the amount of nondiscretionary bonuses and commission that may be used to satisfy the minimum salary threshold to ten percent of the minimum required salary currently $9130 per week or $474760 annually provided that the bonus or commission is paid quarterly or more frequently

What is a nondiscretionary bonus

To better understand what this new provision offers local government employers letrsquos first discuss what counts as a nondiscretionary bonus The distinction between discretionary bonuses and nondiscretionary bonuses is explained at 29 CFR sect 778211 A discretionary bonus is one which may be given or not in the sole judgment of the employer It is up to the manager to decide to which employees and in what amount to award a bonus A nondiscretionary bonus in contrast is one which accrues to the employee automatically as a function of policy or ordinance Bonuses that DOL considers nondiscretionary are

bonuses which are announced to employees to induce them to work more steadily or more rapidly or more efficiently or to remain with the organizationattendance bonuses

Page

individual or group production bonusesbonuses for quality and accuracy of workbonuses contingent upon the employeersquos continuing in employment until the time the payment is to be made (longevity pay for example)

Among public employers longevity pay is the most frequently used form of nondiscretionary bonus Public employers have traditionally paid longevity bonuses once a year To make use of longevity payments in meeting the salary threshold for exempt status those employers will have to change their practices and make longevity payments on either a weekly or a quarterly basis A once-a-year payment may not be in calculating compliance with the salary threshold Relatively few public employers award nondiscretionary merit bonuses based on meeting productivity metrics and there are few public-sector positions that involve commission-based compensation

How Will the Inclusion of Nondiscretionary Bonuses Work in Practice

Effective beginning December 1 2016 and continuing until the next update of the minimum salary threshold on January 1 2020 (on which see below) the amount of nondiscretionary bonus payments that may be credited toward the salary minimum for exemption will be $9130 per week ($474760 annually) (that is 10 of the salary threshold) Employers using nondiscretionary bonuses to meet the salary threshold will need to double-check that employees for whom they are claiming exempt status on this basis are in fact being paid the required minimum salary As a practical matter employers will need to do this on a quarterly basis as DOL is allowing employers to make a ldquocatch-uprdquo payment to bring an employees within the required salary level within one pay period of the end of a quarter DOL explains how this will work in the preamble to the final rule

1 Each pay period an employer must pay the exempt salaried employee at least $82170 (that is 90 percent of the minimum salary threshold

2 At the end of the quarter if the sum of the salary paid plus the nondiscretionary bonuses and incentive payments paid does not equal $11869 (that is the standard salary level multiplied by the 13 weeks of the quarter) the employer is allowed one pay period to make up for shortfall

3 The shortfall cannot exceed $9130 per week or $118690 for the quarter which is 10 percent of the minimum salary threshold

4 Any catch up payment counts toward only the prior quarterrsquos salary amount It will not count toward the salary amount in the quarter in which it ends up actually being paid

An Additional Clarification

The inclusion of nondiscretionary bonuses in the minimum salary threshold does not change any other aspect of the salary basis or salary threshold tests As has always been the case under the FLSA discretionary bonuses employer contributions to health disability and life insurance and employer contributions to LGERS and the North Carolina 401(k) Plan may not be included in the calculation of whether an employeersquos salary meets the minimum salary threshold

The provision allowing the use of nondiscretionary bonuses and commissions in up to 10 of the amount of the minimum salary threshold will be found at 29 CFR sect 541602(a)(3 effective December 1 2016

The Highly Compensated Employee Salary Threshold

DOL also increased the minimum salary necessary for a position to qualify as exempt under the special highly-compensated employee exemption from $100000 to $134004 annually The new threshold is set at the 90 percentile of earnings of all full-time employees nationally for the last quarter of 2015

Currently employees can be exempt if they are paid $100000 annually and perform just one of the exempt duties of the executive administrative or professional duties tests The idea behind the highly-compensated employee exemption is that the very high salary threshold offsets this exemptionrsquos minimal duties test The current highly-compensated exemption allows for compensation in excess of $455 per week to be in the form of nondiscretionary bonuses or commissions and allows employers to make a final ldquocatch-uprdquo payment to bring the employeersquos salary up to $100000 per year within one month after the end of the year

Page

As before employers making use of the highly-compensated employee exemption will be able to use nondiscretionary bonuses and commissions in any amount in calculating the minimum salary provided that the employee makes at least $913 per week (in other words the ten percent limitation applicable to the standard salary threshold does not apply here) Employers will also be allowed to make a final ldquocatch-uprdquo payment to bring the employeersquos salary up to $134004 by the end of January of the following year

The new minimum salary threshold for highly compensated employee will be found at 29 CFR sect 541601 effective December 1 2016

Automatically Updating the Minimum Salary Threshold

In the past the minimum salary threshold has been updated sporadically DOL is now instituting a regular automatic update to 1) ensure the salary threshold maintains its effectiveness as a bright line rule to distinguish between exempt and nonexempt positions and 2) make changes to the threshold more predictable for employers DOL will now update the minimum salary threshold every three years The first update will be effective on January 1 2020 It will be based on the 40th percentile of earnings of full-time salaried employees in the lowest-wage census region DOL projects that the threshold will be $984 per week ($51168 annually) beginning in 2020 For employees for whom employers are seeking an exemption under the highly-compensated employee test the salary threshold will be set at the 90th percentile of earnings of full-time salaried employees nationally DOL projects that the highly compensated employee salary threshold will be $147524 beginning in 2020

DOL will publish the updated salary thresholds in the Federal Register at least 150 days before the effective date (in other words the notice of the January 1 2020 update should be published in the Federal Register no later than August 4 2019) It will also post information about the updated thresholds on its website

The new rule providing for automatic updating will be at 29 CFR sect 541607 effective December 1 2016

The Duties Tests Have Not Been Revised

In the proposed rule DOL floated the possibility of revising the executive administrative and professional duties tests The Department expressed concern that the current tests allow exempt employees to performing a disproportionate amount of nonexempt work along with their exempt work The new rule does not include any changes to the duties tests

Overtime Provisions That Will Not Change

The new rule will have a significant impact on public employers turning many employees who are currently exempt from overtime into nonexempt employees These newly nonexempt employees will now need to be compensated at one-and-one-half times their regular rate of pay whenever they work more than 40 hours in a workweek The new rule will not however change any of the other FLSA provisions relating to overtime

Public employers may continue to use compensatory time-off or ldquocomp timerdquo in lieu of cash overtime On comp time see herePublic employers may still use the 28-day work cycle of the 207(k) exempt for paying overtime to law enforcement officers and firefighters On the 207(k) exemption see hereThe fluctuating workweek will continue to be available as a method of paying overtime to those employees who sometimes work fewer than 40 hours per week and sometimes work more than 40 hours per week On the fluctuating workweek method see hereSmall employers who have fewer than five law enforcement officers on the payroll in any workweek or fewer than five firefighters on the payroll in any workweek continue to be exempt from paying overtime to those officers and firefighters in those workweeksThe rules governing what time is compensable and what is not remain the same

For those interested in learning more about the new overtime rule including how the revised rule will effect public employers and what options public employers have for dealing with the challenges the new rule poses to their budgets please join me for the School of Governmentrsquos webinar The New (and Final) FLSA Overtime Regulations on June 6 2016 at 10 am

Page

Registration is $125 per site (for an unlimited number of participants) and may be found here

Links

wwwgpogovfdsyspkgFR-2016-05-23pdf2016-11754pdfwwwlawcornelleducfrtext29778211unclive1TCxyzy

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Coates Canons Blog The FLSArsquos Overtime Pay Provisions for Law Enforcement and Firefighting Employees

By Diane Juffras

This entry was posted on March 18 2015 and is filed under Compensation amp Benefits Fair Labor Standards Act General Local Government (Miscellaneous)

The Fair Labor Standards Act has two exceptions from its overtime pay rules for nonexempt employees who work different numbers of hours from week to week the fluctuating workweek method and the section 207(k) exemption for law enforcement officers and firefighters Look here for a post I wrote about the fluctuating workweek method which can be used for any employee whose hours fluctuate This post discusses the 207(k) exception which is limited to law enforcement officers and firefighters It is called the 207(k) exemption because it is found at 29 USC sect 207(k) (it is sometimes called the 7(k) exemption after its location in the original bill) The 207(k) exemption is well-liked by law enforcement agencies and fire departments because it makes calculating the overtime of their employees more efficient and because it reduces overtime costs in a small but real way

Background

The FLSA requires employers to pay employees at a rate of one-and-one-half times their regular rate of pay for each hour worked over 40 in a week (unless they are exempt) Law enforcement officers and firefighters present a bookkeeping and payroll challenge because they frequently work shifts of 12- or 24-hours and may be scheduled to work these shifts several days in a row piling up a lot of hours quickly In that sense law enforcement officers and firefighters work the ultimate fluctuating workweek

How the 207(k) Exemption Works

The 207(k) exemption allows public employers to figure overtime compensation for law enforcement and fire employees on the basis of work periods longer than the one-week work periods that apply to all other employees The work period can be as long as 28 days The employer still maintains whatever payroll schedule that it prefers ndash weekly bi-weekly or monthly ndash and law enforcement officers and firefighters still get paid on that schedule But overtime premium pay for law enforcement officers and firefighters is determined and paid out at the end of the 207(k) work period

When a law enforcement agency adopts the longest possible work period ndash 28 consecutive days ndash officers earn time-and-one-half overtime pay only after they have worked 171 hours within that 28-day work period For firefighters on a 28-day work schedule overtime is earned only after 212 hours

The FLSA regulations allow law enforcement and fire departments to use the 207(k) exemption for work periods of anylength between seven and 28 days and to prorate accordingly the number of hours that must be worked before overtime kicks in Most departments use work periods that are multiples of seven Those multiples work out this way

Law Enforcement Fire Protection

28 days 171 hrs 212 hrs

Page

As noted earlier an employer does not have to alter its pay schedule to align with a 207(k) work period For example

Suppose the employing department has chosen a 28-day work schedule and the employer pays its employees on a weekly basis In that case employees working under the 207(k) exemption receive their regular straight-time rate for all of the hours they have worked on each of the first three weekly pay periods on the 28-day cycle They receive their regular straight-time compensation and any overtime due for that 28-day pay period on the final weekly pay period of that cycle

Suppose the employing department has chosen a 28-day work schedule and the employer pays its employees on a bi-weekly basis In that case employees working under the 207(k) exemption receive their regular straight-time rate for all of the hours they have worked during the first two weeks on the first bi-weekly pay period of the 28-day cycle They receive their regular straight-time compensation for the second two weeks and any overtime due for that 28-day pay period on the second bi-weekly pay period of that cycle

The 207(k) Exemption and Comp Time

Employees scheduled in accordance with section 207(k) may be compensated for overtime hours worked with compensatory time off rather than with cash overtime pay just like employees on a regular one-week work period For the regulation see here

Establishing the 207(k) Exemption

Law enforcement agencies and fire departments do not have to obtain permission from either the US Department of Labor or their employees to adopt a 28-day work schedule and use the 207(k) exemption The do however have to satisfy two requirements First the adoption of the schedule must be documented in the employerrsquos payroll records along with the length of the work period (that is 28-days 14-days or whatever it is) and the starting date and time of each work period Second the payroll notation must state that the schedule has been adopted ldquopursuant to section 207(k) of the FLSA and 29 CFR Part 553rdquo (see here for this requirement)

Who Qualifies as a Law Enforcement Officer or Firefighter for 207(k) Purposes

Not every employee of a law enforcement agency or fire department may be compensated using the 207(k) exemption The exemption is limited to sworn law enforcement officers and to those with the legal authority to fight fires

For the purposes of the 207(k) exemption the FLSA regulations define law enforcement officers as

uniformed or plainclothes members of a body of officerswho have the statutory power to enforce the law andwho have the power to arrest andwho have participated in a special course of law enforcement training

The regulations provide that an unsworn jailer counts as a law enforcement officer for 207(k) purposes but other civilian employees of the police or sheriffrsquos department do not

A firefighter is defined for 207(k) purposes as ldquoan employee including a firefighter paramedic emergency medical technician rescue worker ambulance personnel or hazardous materials workerrdquo whomdash

is trained in fire suppression andhas the legal authority and responsibility to engage in fire suppression andis employed by a fire department of a municipality county fire district or State andis engaged in the prevention control and extinguishment of fires or response to emergency situations where life property or the environment is at risk

No other employees of a fire department may be compensated using the 207(k) exemption

Page

Other Public Safety Employees

Some jurisdictions place emergency medical personnel under the supervision of a law enforcement agency or a fire department This arrangement is lawful and makes organizational sense for some cities and counties But employees whose primary job duties are the provision of emergency medical services do not qualify for the 207(k) exemption unless they meet the statutory and regulatory definitions of either a law enforcement officer or a firefighter Several North Carolina local governments cross-train and cross-utilize their public safety personnel in this way but they are the exception and not the rule

Citations

The regulations covering the issues discussed in this blog post and not otherwise linked in the text may be found here here here here here and here

Links

wwwlawcornelleduuscodetext29207wwwlawcornelleducfrtext29553231wwwlawcornelleducfrtext2955351wwwlawcornelleducfrtext29553211wwwlawcornelleducfrtext29553210wwwlawcornelleducfrtext29553201wwwlawcornelleducfrtext29553220wwwlawcornelleducfrtext29553221wwwlawcornelleducfrtext29553224wwwlawcornelleducfrtext29553230

Page

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Coates Canons Blog Understanding the Fair Labor Standards Actrsquos Fluctuating Workweek

By Diane Juffras

This entry was posted on January 15 2015 and is filed under Compensation amp Benefits Employment Fair Labor Standards Act General Local Government (Miscellaneous)

John is an EMS dispatcher whose hours vary unpredictably from week to week John always works at least 40 hours per week but some weeks John works 42 hours some weeks he works 48 hours and occasionally he works close to 60 Ellen is a water plant operator who weekly hours vary as well but they vary on a scheduled basis Ellen works 32 hours every first and third week of the month and 48 hours every second and fourth week Both John and Ellen are nonexempt employees The city for which John and Ellen work pays cash overtime instead of using compensatory time off Yet neither John nor Ellen earns overtime at the rate of time-and-one-half Without violating the FLSA the city pays both John and Ellen at just one-half their regular rate of pay for each hour over 40 that they work in a given work week How can that be

Background

The Fair Labor Standards Act (FLSA) requires employers to pay time-and-one-half the regular rate of pay for all hours over 40 that an employee works in a given week unless the employee is ldquoexemptrdquo That is unless the employee meets either the executive administrative or professional duties tests (for how to determine whether an employee is exempt or nonexempt under the FLSA see my previous blog posts here here here here and here)

But for some employees there is another way to go about it

The Fluctuating Workweek Alternative

The text of the Fair Labor Standards Act itself says nothing about fluctuating workweeks but the US Department of Laborrsquos regulations implementing the FLSA set out an entire sectionmdash29 CFR sect 778114mdashexplaining the circumstances under which employers may use an alternate method of calculating overtime when employees work hours that fluctuate from week to week This method is called the ldquofluctuating workweek methodrdquo It provides for a) the payment of an unchanging salary that compensates the employee for all hours worked that week regardless of whether the employee works fewer or greater than 40 hours a week and b) payment for overtime hours at a rate of one-half the employeersquos regular rate of pay

To use the fluctuating workweek method of payment five requirements must be met

1 the employee must work hours that fluctuate from week to week2 the employee must be paid a fixed salary that serves as compensation for all hours worked3 the fixed salary must be large enough to compensate the employee for all hours worked at a rate not less than the

minimum wage4 the employee must be paid an additional one-half of the regular rate for all overtime hours worked and5 there must be a ldquoclear mutual understandingrdquo that the fixed salary is compensation for however many hours the

employee may work in a particular week rather than for a fixed number of hours per week

Letrsquos look at each of the requirements in turn

1 The Employee Must Work Fluctuating Hours

The regulation says that this method of payment may be used for employees with ldquohours of work which fluctuate from week to weekrdquo and that it is ldquotypicallyrdquo used to pay ldquoemployees who do not customarily work a regular schedule of hoursrdquo Nevertheless nothing in the regulation requires that the employeersquos hours be unpredictable or unknowable in advance Two federal Fourth Circuit Court of Appeals decisions make that clear In both Flood v New Hanover County and Griffin v Wake County

Page 1

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Page 1

the court found that a work schedule in which the employeersquos hours varied on a regular predictable basis satisfied the requirement that the employeersquos hour fluctuate from week to week

In addition nothing requires that the fluctuation include some weeks where the hours worked are fewer than 40 and some where the hours worked are greater than 40 All the regulation requires is that the employeersquos hours fluctuate from week to week In the Flood case the Fourth Circuit held that the employer could the fluctuating workweek method to compensate employees working a rotating schedule of 483 563 6445 and 7245 hours per week The Seventh Circuit Court of Appeals reached a similar conclusion in the case Condo v Sysco Corp

Thus in the example above both John (who works unpredictable hours but always more than 40 hours per week) and Ellen (whose schedule varies on a regular basis) may be compensated using the fluctuating workweek method of payment

2 The Employee Must Be Paid a Fixed Salary

The fluctuating workweek method of payment requires that the employer pay the employee a fixed salary for each week The amount cannot vary based on the number of hours worked In the example above John the EMS dispatcher is paid $67500 week while Ellen the water plant operator is paid $800 per week John is paid $67500 whether his work week is 42 48 or 57 hours in any given week Ellen is paid $80000 whether she is working one of the 32-hour weeks or one of the 48-hour weeks on her schedule And it should be noted Johnarsquos salary for a week would still be $67500 if during that particular week he worked only 30 hours for some reason

3 The Rate Must Be At Least That of the Minimum Wage

The salary used to compensate an employee under the fluctuating workweek method can be of any amount with only one proviso the salary must be large enough that the regular ratemdashthe amount found by dividing the fixed salary by the total number of hours worked in any weekmdashis at least equal to the minimum wage The regular rate of pay will vary due from week to week because the hours that the employee works fluctuate from week to week Even in a week where John the dispatcher works 57 hours his regular rate of pay remains above the minimum wage ($67500 cedil 57 = $1185hour)

4 Overtime Hours Are Compensated at One-Half the Regular Rate

Under the fluctuating workweek method the fixed salary is defined as compensation for all hours that an employee has worked in any workweek That is the payment of the salary is compensation at the regular rate of pay for all of the hours the employee works in that week including overtime hours In other words for the hours below 40 the employee is compensated by the fixed salary and for hours over forty the employee is compensated for the ldquotimerdquo in ldquotime-and-one-halfrdquo the regular rate by the fixed salary Since employer has already paid the employee the regular rate for all of the hours he or she has worked by payment of the salary the employer owes the employee only one-half of the regular rate for the hours over 40

Thus if John the EMS dispatcher works 495 hours one week his employer must pay him his fixed salary of $67500 and 95 hours of overtime pay at one-half his regular rate of pay for that week On weeks during which Ellen the water plant operator works 32 hours she receives her fixed salary of $80000 ndash no more and no less On weeks in during which Ellen works 48 hours her employer must pay her fixed salary of $80000 and 8 hours of overtime pay at one-half her regular rate of pay

5 Employer and Employee Must Have a ldquoClear Mutual Understandingrdquo That the Salary Is for All Hours Worked Not for a Specified Number of Hours

Usually when an employer pays a nonexempt employee on a salaried basis (for a discussion of what ldquosalary basisrdquo means see here) employer and employee understand that the salary is meant to compensate the employee for a regular schedule with a fixed set of hours An employer may only use the fluctuating workweek method only if it has been made clear to the employeemdashbefore he or she works any hours under this payment methodmdashthat a) the fixed salary will be compensation for however many hours the employee works in a week and that the salary will not increase in weeks in which the employee works a greater number of hours and b) any hours over 40 will be compensated at one-half the regular rate for that week

Page 2

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Page 2

The Fourth Circuit has made clear that employees do not have to ldquoagreerdquomdashin the sense of ldquoconsentrdquomdashto the use of the fluctuating workweek method They merely have to be told about its use

Why Use the Fluctuating Workweek Method

For most employers the primary reason for using the fluctuating workweek method is to reduce overtime costs The US Department of Labor and the federal courts take pains to emphasize that the fluctuating workweek method is not an exception to the overtime rule but is merely an alternative method of paying overtime Theoretically an employer using the fluctuating workweek method is already paying some of the costs of overtime upfront in the fixed salary and neither employer nor employee is receiving a break or being cheated

In reality however employers pay only a third (one-half of the regular rate) of the additional amount that must be paid to a nonexempt employee working more than 40 hours a week Where overtime hours are unpredictable this reduces the amount of potentially unbudgeted overtime liability Because the regular rate is calculated anew each week based on the total number of straight and overtime hours worked that week the cost of overtime to the employer goes down the greater the number of overtime hours an employee works

From an employeersquos perspective on the other hand it looks like the greater the number of hours worked the less the employee is paid Not surprisingly the fluctuating workweek is not popular for employees who work a substantial amount of overtime For those employees who work fewer than 40 hours a week on a recurring basis however the fluctuating workweek can provide a more predictable income

Conclusion

Local government employers who have employees whose hours vary from week to week may choose to use the fluctuating workweek method of payment but they do not have to This method may be used to compensate dispatchers emergency medical services personnel law enforcement officers and firefighters water and wastewater plant operators and any other positions where operating needs require scheduling that results in workweeks in which the number of hours worked changes from week to week It may not be used for employees (law enforcement officers and firefighters) who are being compensated under the section 207(k) exemption

Links

wwwlawcornelleducfrtext29778114openjuristorg125f3d249flood-v-new-hanover-countyopenjuristorg142f3d712griffin-v-wake-countyopenjuristorg1f3d599condo-v-sysco-corporation

Page 3

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Page 3

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Coates Canons Blog Internships under the Fair Labor Standards Act

By Diane Juffras

This entry was posted on March 19 2014 and is filed under Compensation amp Benefits Employment Fair Labor Standards Act General Local Government (Miscellaneous)

Look at two interns Tim is a twenty-year old college student majoring in accounting He expresses interest in an internship with the cityrsquos finance department over the summer Chris a high school athlete applies for a position as an intern working in the cityrsquos summer camp program The city offers them the internships Tim is offered a stipend of $2500 for ten weeks of full-time work Chris is told he will not be paid at all

Are these arrangements lawful It may come as a surprise but in paying Tim a stipend of $2500 the city is violating the Fair Labor Standards Act (FLSA) In not paying Chris anything on the other hand the city is in compliance with the FLSA How can this be so

Some high school and college students land actual summer ldquojobsrdquo Employers hire them as temporary employees and pay them at least the federal minimum wage But increasing numbers of employers and students enter into the murky relationship known as an internship a student performs services for the employer in return for which the student may receive lump sum compensation known as a stipend or sometimes no compensation at all From the studentrsquos perspective a good internship gives something that can be more valuable than money practical experience that may lead to a real job in a particular field after graduation From an employerrsquos perspective a good intern performs useful work at less than the cost of a full-time employee Interns also can form a pool from which to seek new employees in the future

The FLSA and its regulations issued by the US Department of Labor make no mention of interns or internships except for one mention of ldquoCongressional internsrdquo and another of medical interns who have already received their medical degrees For this reason many employers assume that internship arrangements are not affected by the FLSA The fact that internships are not addressed by the FLSA however means something very different It means that the FLSA does not recognize the internship arrangement as an exception to its requirement that employees must be paid the minimum wage and possibly depending on the nature of the services overtime compensation after 40 hours in a single workweek

Paying an Intern a Stipend Whose Pro Rata Rate of Pay is Less Than the Minimum Wage is Unlawful

Letrsquos return to Tim He is working what is a full-time schedule for the city mdash 40 hours per week ndash for the ten weeks of his summer He is being paid the lump sum of $2500 That works out to $626 per hour a full $100 per hour less than the federal minimum wage ldquoWhatrsquos wrong with thatrdquo many may think After all Tim is a college student He hasnrsquot earned his degree yet and has no previous experience working in a municipal finance office Whatever Tim learns over the course of the summer and however proficient he becomes at the particular duties he is assigned will be of no ongoing benefit to the city because Tim will go back to school at the end of the summer

However reasonable this argument may seem as long as Tim is doing work for the city he is ldquoemployedrdquo within the meaning of the Fair Labor Standards Act That is he is ldquosuffered or permitted to workrdquo Under those circumstances Tim is an employee and he must be paid the minimum wage This rule generally applies to internships in both the public and private sectors

Public Sector Internships May Be Unpaid

Chrisrsquos situation is altogether different In providing services for the cityrsquos summer camp without expectation of compensation Chris is a volunteer a term and concept which is addressed at length in the FLSA regulations Under the FLSA an individual who performs service for a public agency for civic charitable or humanitarian reasons without promise expectation or receipt of compensation for services rendered services is a volunteer if

1 the individual in fact receives no compensation or is paid only expenses reasonable benefits or a nominal fee to

Page 1

httpcanonssoguncedu

Page 1

perform the services for which the individual volunteered2 their services are offered freely and without pressure or coercion direct or implied from an employer and3 the individual is not otherwise employed by the local government to perform the same type of services

Here Chris receives no compensation for his camp counselor activities and he has offered them to the city of his own accord He is not employed by the city He and the city may call his position an internship for the purposes of building Chrisrsquos resume and giving his experience working with the camprsquos children a more impressive title but as a legal matter Chris is a volunteer

Public-sector Interns May Be Reimbursed for Expenses

Could Chris be paid anything and still maintain his volunteer status The answer to this question is ldquoyesrdquo Volunteers may be paid expenses reasonable benefits a nominal fee or combination of the three without losing their status as volunteers So for example if the city requires its camp counselors to wear Carolina-blue colored t-shirts every day it may give Chris and its other volunteer counselors a uniform allowance to cover the cost of five t-shirts If Chrisrsquos duties involve coaching softball at the camp and his pants all end up covered in dust or ripped at the knee the city may reimburse him for reasonable cleaning expenses or for wear and tear The city may also reimburse Chris for out-of-pocket expenses incurred while working as a camp volunteer such as payment for the cost of meals or transportation expenses The FLSA regulations provide several other examples of allowable reimbursements here The most important point to remember is that reimbursements must be of actual expenses and that no amount paid to a volunteer should be based on productivity or hours of service

Look at Timrsquos situation again He could have volunteered his services to the finance department The city could have paid him nothing As in Chrisrsquos case he and the city could call his service an internship if they so choose But as far as compensation goes the city has a clear choice to make it can either pay him the minimum wage for all hours worked up to 40 hours per week and time-and-one-half overtime for any hours over 40 or it can treat him as a volunteer paying him nothing and at its discretion reimbursing him for any reasonable expenses Paying him a stipend of $2500 (equivalent to $625 per hour) satisfies neither alternative requirement and violate the FLSA

Private-Sector Internships May Be Unpaid Only in Very Limited Circumstances

Maybe you have heard of the US Department of Laborrsquos test for interns Why havenrsquot I used it to analyze the hypothetical examples of Timrsquos and Chrisrsquos situations There is in fact a safe-harbor test for the use of unpaid interns It is a stringent test The catch is that it applies only to private-sector employers It does not apply to the city where Tim and Chris are interns

The US Department of Labor and the federal courts have set forth a six-part test for the use of unpaid interns by private employers DOLrsquos latest articulation of this test may found herein the Wage and Hour Divisionrsquos Fact Sheet 71 Under this test the use of unpaid interns by private employers is unlawful unless the internship arrangement meets the following requirements

1 the internship even though it includes actual operation of the facilities of the employer is similar to training which would be given in an educational environment

2 the internship experience is for the benefit of the intern3 the intern does not displace regular employees but works under close supervision of existing staff4 the employer that provides the training derives no immediate advantage from the activities of the intern and on

occasion its operations may actually be impeded5 the intern is not necessarily entitled to a job at the conclusion of the internship and6 the employer and the intern understand that the intern is not entitled to wages for the time spent in the internship

If any one of the above criteria are not met then the intern is an employee must be paid minimum wage Very few internship arrangements meet this test as most employers desire to gain some benefit from bringing an intern into the organization and many feel they must offer some form of compensation (remember a ldquostipendrdquo is just ldquowagesrdquo by another name)

Future Public-Sector Guidance May Be Forthcoming from DOL

At the bottom of Fact Sheet 71 in a footnote the Wage and Hour Division (WHD) of DOL acknowledges the existence of

Page 2

httpcanonssoguncedu

Page 2

the internship dilemma in the public sector and says

The FLSA makes a special exception under certain circumstances for individuals who volunteer to perform services for a state or local government agency and for individuals who volunteer for humanitarian purposes for private non-profit food banks WHD also recognizes an exception for individuals who volunteer their time freely and without anticipation of compensation for religious charitable civic or humanitarian purposes to non-profit organizations Unpaid internships in the public sector and for non-profit charitable organizations where the intern volunteers without expectation of compensation are generally permissible WHD is reviewing the need for additional guidance on internships in the public and non-profit sectors (emphasis added)

Conclusion

In the public sector interns can be true volunteers or they can be employees There is no legally in-between status of ldquointernrdquo Public employers have a choice with respect to interns They may freely avail themselves of the services of ldquointernsrdquo if they treat them as volunteers and do not pay them any more than reimbursement of direct expenses or a de minimis token of appreciation Or they may treat them as employees and pay at least minimum wage (and maybe overtime) A public employer may not pay ldquointernsrdquo a stipend that amounts to less than the minimum wage If a public employer wishes to pay an intern a stipend then the intern becomes a temporary employee subject to minimum wage and all of the other applicable requirements of the FLSA

Links

wwwlawcornelleducfrtext29553101wwwlawcornelleducfrtext29553106wwwdolgovwhdregscompliancewhdfs71pdf

Page 3

httpcanonssoguncedu

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US Department of Labor Wage and Hour Division

(April 2010)

Fact Sheet 71 Internship Programs Under The Fair Labor Standards Act This fact sheet provides general information to help determine whether interns must be paid the minimum wage and overtime under the Fair Labor Standards Act for the services that they provide to ldquofor-profitrdquo private sector employers Background The Fair Labor Standards Act (FLSA) defines the term ldquoemployrdquo very broadly as including to ldquosuffer or permit to workrdquo Covered and non-exempt individuals who are ldquosuffered or permittedrdquo to work must be compensated under the law for the services they perform for an employer Internships in the ldquofor-profitrdquo private sector will most often be viewed as employment unless the test described below relating to trainees is met Interns in the ldquofor-profitrdquo private sector who qualify as employees rather than trainees typically must be paid at least the minimum wage and overtime compensation for hours worked over forty in a workweek The Test For Unpaid Interns There are some circumstances under which individuals who participate in ldquofor-profitrdquo private sector internships or training programs may do so without compensation The Supreme Court has held that the term suffer or permit to work cannot be interpreted so as to make a person whose work serves only his or her own interest an employee of another who provides aid or instruction This may apply to interns who receive training for their own educational benefit if the training meets certain criteria The determination of whether an internship or training program meets this exclusion depends upon all of the facts and circumstances of each such program The following six criteria must be applied when making this determination

1 The internship even though it includes actual operation of the facilities of the employer is similar to

training which would be given in an educational environment

2 The internship experience is for the benefit of the intern

3 The intern does not displace regular employees but works under close supervision of existing staff

4 The employer that provides the training derives no immediate advantage from the activities of the intern

and on occasion its operations may actually be impeded

5 The intern is not necessarily entitled to a job at the conclusion of the internship and

6 The employer and the intern understand that the intern is not entitled to wages for the time spent in the

internship

If all of the factors listed above are met an employment relationship does not exist under the FLSA and the Actrsquos minimum wage and overtime provisions do not apply to the intern This exclusion from the definition of employment is necessarily quite narrow because the FLSArsquos definition of ldquoemployrdquo is very broad Some of the most commonly discussed factors for ldquofor-profitrdquo private sector internship programs are considered below

Similar To An Education Environment And The Primary Beneficiary Of The Activity In general the more an internship program is structured around a classroom or academic experience as opposed to the employerrsquos actual operations the more likely the internship will be viewed as an extension of the individualrsquos educational experience (this often occurs where a college or university exercises oversight over the internship program and provides educational credit) The more the internship provides the individual with skills that can be used in multiple employment settings as opposed to skills particular to one employerrsquos operation the more likely the intern would be viewed as receiving training Under these circumstances the intern does not perform the routine work of the business on a regular and recurring basis and the business is not dependent upon the work of the intern On the other hand if the interns are engaged in the operations of the employer or are performing productive work (for example filing performing other clerical work or assisting customers) then the fact that they may be receiving some benefits in the form of a new skill or improved work habits will not exclude them from the FLSArsquos minimum wage and overtime requirements because the employer benefits from the internsrsquo work Displacement And Supervision Issues If an employer uses interns as substitutes for regular workers or to augment its existing workforce during specific time periods these interns should be paid at least the minimum wage and overtime compensation for hours worked over forty in a workweek If the employer would have hired additional employees or required existing staff to work additional hours had the interns not performed the work then the interns will be viewed as employees and entitled compensation under the FLSA Conversely if the employer is providing job shadowing opportunities that allow an intern to learn certain functions under the close and constant supervision of regular employees but the intern performs no or minimal work the activity is more likely to be viewed as a bona fide education experience On the other hand if the intern receives the same level of supervision as the employerrsquos regular workforce this would suggest an employment relationship rather than training Job Entitlement The internship should be of a fixed duration established prior to the outset of the internship Further unpaid internships generally should not be used by the employer as a trial period for individuals seeking employment at the conclusion of the internship period If an intern is placed with the employer for a trial period with the expectation that he or she will then be hired on a permanent basis that individual generally would be considered an employee under the FLSA Where to Obtain Additional Information This publication is for general information and is not to be considered in the same light as official statements of position contained in the regulations For additional information visit our Wage and Hour Division Website httpwwwwagehourdolgov andor call our toll-free information and helpline available 8 am to 5 pm in your time zone 1-866-4USWAGE (1-866-487-9243) US Department of Labor Frances Perkins Building 200 Constitution Avenue NW Washington DC 20210

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

The FLSA makes a special exception under certain circumstances for individuals who volunteer to perform services for a state or local government agency and for individuals who volunteer for humanitarian purposes for private non-profit food banks WHD also recognizes an exception for individuals who volunteer their time freely and without anticipation of compensation for religious charitable civic or humanitarian purposes to non-profit organizations Unpaid internships in the public sector and for non-profit charitable organizations where the intern volunteers without expectation of compensation are generally permissible WHD is reviewing the need for additional guidance on internships in the public and non-profit sectors

(Revised July 2009)

Fact Sheet 16 Deductions From Wages for Uniforms and Other Facilities Under the Fair Labor Standards Act (FLSA)

This fact sheet provides general information concerning the application of the FLSA to deductions from employees wages for uniforms and other facilities

Characteristics The FLSA does not allow uniforms or other items which are considered to be primarily for the benefit or convenience of the employer to be included as wages Thus an employer may not take credit for such items in meeting hisher obligations toward paying the minimum wage or overtime

Requirements Uniforms The FLSA does not require that employees wear uniforms However if the wearing of a uniform is required by some other law the nature of a business or by an employer the cost and maintenance of the uniform is considered to be a business expense of the employer If the employer requires the employee to bear the cost it may not reduce the employees wage below the minimum wage of $725 per hour effective July 24 2009 Nor may that cost cut into overtime compensation required by the Act For example if an employee who is subject to the statutory minimum wage of $725 per hour (effective July 24 2009) is paid an hourly wage of $725 the employer may not make any deduction from the employees wages for the cost of the uniform nor may the employer require the employee to purchase the uniform on hisher own However if the employee were paid $775 per hour and worked 30 hours in the workweek the maximum amount the employer could legally deduct from the employees wages would be $1500 ($50 X 30 hours) The employer may prorate deductions for the cost of the uniform over a period of paydays provided the prorated deductions do not reduce the employees wages below the required minimum wage or overtime compensation in any workweek Other Items Employers at times require employees to pay or reimburse the employer for other items The cost of any items which are considered primarily for the benefit or convenience of the employer would have the same restrictions as apply to reimbursement for uniforms In other words no deduction may be made from an employees wages which would reduce the employees earnings below the required minimum wage or overtime compensation

Some examples of items which would be considered to be for the benefit or convenience of the employer are tools used in the employees work damages to the employers property by the employee or any other individuals financial losses due to clientscustomers not paying bills and theft of the employers property by

FS 16

the employee or other individuals Employees may not be required to pay for any of the cost of such items if by so doing their wages would be reduced below the required minimum wage or overtime compensation This is true even if an economic loss suffered by the employer is due to the employees negligence Employers may not avoid FLSA minimum wage and overtime requirements by having the employee reimburse the employer in cash for the cost of such items in lieu of deducting the cost from the employees wages Typical Problems (1) A minimum wage employee working as a cashier is illegally required to reimburse the employer for a cash drawer shortage (2) An employer improperly requires tipped employees to pay for customers who walk out without paying their bills or for incorrectly totaled bills (3) An employer furnishes elaborate uniforms to employees and makes them responsible for having the uniforms cleaned (4) An employee driving the employers vehicle causes a wreck and the employer holds the employee responsible for the repairs thereby reducing the employees wages below the minimum wage (5) A security guard is required to purchase a gun for the job and the cost causes himher to not earn the minimum wage (6) The cost of an employer-required physical examination cuts into an employees minimum wage or overtime compensation Where to Obtain Additional Information For additional information visit our Wage and Hour Division Website httpwwwwagehourdolgov andor call our toll-free information and helpline available 8 am to 5 pm in your time zone 1-866-4USWAGE (1-866-487-9243) This publication is for general information and is not to be considered in the same light as official statements of position contained in the regulations US Department of Labor Frances Perkins Building 200 Constitution Avenue NW Washington DC 20210

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

US Department of Labor Employment Standards Administration Wage and Hour Division Washington DC 20210

February 16 2001

FLSA2001-7 Dear Name This is in response to your letter to former Administrator Maria Echaveste concerning the requirements of the Fair Labor Standards Act (FLSA) and its regulations on deductions from wages for the cost of uniforms including weapons for police officers We regret the delay in responding You request a formal opinion on whether it would be proper under the FLSA for an employer to deduct the cost of uniforms from an employeersquos wages in a week in which that employee works more than 40 hours if the employer pays the employee overtime compensation computed at 1 frac12 times the regular rate (before deductions are taken out) and if the deduction does not reduce the regular rate below the minimum wage required by the FLSA In other words may the deduction be made where the employeersquos weekly wage and overtime are calculated at the proper rates and then the deduction is taken out of the employeersquos gross wage without reducing the overtime compensation or reducing the employeersquos pay below the minimum wage To best respond to your inquiry it may be helpful to review the Divisionrsquos interpretation of the legal requirements for deductions in general Employers must pay employees statutorily-required minimum wage and overtime premium pay finally and unconditionally or ldquofree and clearrdquo Section 3(m) of the FLSA allows an employer to count as part of wages the reasonable cost to the employer of furnishing an employee with ldquoboard lodging or other facilitiesrdquo when the employer customarily furnishes the items to employees unless a bona fide collective bargaining agreement excludes such costs from wages An employer may either claim a credit towards its minimum wage and overtime obligations for the reasonable cost or fair value of furnishing qualifying section 3(m) facilities or deduct the amounts from the compensation due even if the qualifying section 3(m) deductions reduce an employeersquos pay below the statutorily-required minimum The costs of furnishing items to employees that are primarily for the benefit or convenience of the employer are not recognized as ldquoreasonablerdquo They can never qualify as ldquosection 3(m) facilitiesrdquo and may not therefore be counted as a part of wages statutorily due Consequently if an employee returns to the employer (or to someone else on the employerrsquos behalf) any part of his or her wage entitlements due (whether returned in cash or in other than cash -- eg tools or equipment) violations result Violations occur in two ways (1) directly when an employer deducts from an employeersquos pay the cost of furnishing the employee a non-3(m) item or (2) indirectly when the employee must incur out-of-pocket expenses to buy the item and the employer fails to reimburse the employee for the outlay See Regulations 29 CFR sectsect5313(d)(1) and (3) 53132(c) and 53135 It makes no difference whether an employer requires an employee to purchase a tool or equipment before the employee begins work or during the course of the work ndash both situations present potential violations if the employee acquires the item in connection with the employment relationship If an employer requires a prospective employee to purchase a uniform before starting work the employer must reimburse the employee no later than the next regular payday to the extent that the uniform costs cut into statutory minimum wage or overtime premium pay These same principles apply to the costs of furnishing any tools or equipment required by other law (eg State law) by the nature of the work or by the employer Under these principles an employer may not lawfully require an employee to pay for an expense of the employerrsquos business if doing so reduces the employeersquos pay below any statutorily-required minimum wage or overtime premium pay For example tools of the trade and other materials or equipment incidental to carrying on the employerrsquos business and the cost of uniforms or other equipment where the nature of the business or work requires the employee to have them are considered business expenses of the employer that do not qualify as ldquosection 3(m) facilitiesrdquo An employer may not require employees to

Working to Improve the Lives of Americas Workers Page 1 of 3

incur costs for such non-3(m) items if doing so cuts into their statutory minimum wage or overtime premium pay entitlements Regulations 29 CFR sect53137 contains our interpretations on deductions from wages for non-3(m) items in overtime workweeks Briefly deductions for articles that do not qualify as ldquoboard lodging or other facilitiesrdquo under FLSA section 3(m) may be made in an overtime workweek to the same extent as in a non-overtime workweek if their purpose and effect are not to evade the overtime requirements of the FLSA or other law and provided the situation involves bona fide deductions that are made for particular items according to an agreement or understanding between the employer and the employee (29 CFR sect53137(a)) If all these conditions are met the total amount that an employer may deduct from an employee subject to overtime pay in an overtime workweek may not exceed the amount that could be deducted if the employee had only worked a 40-hour week If an employer makes bona fide deductions from the stipulated wage of an employee the employeersquos regular rate for calculating statutory time-and-one-half overtime pay is the stipulated wage before the deductions are made (29 CFR sect53137(b)) Note too that under 29 CFR sect778315 employers must pay employees all of their straight time compensation due under an express or implied contract or under any applicable statute for the non-overtime hours worked before it can be said that the employer has paid proper time-and-one-half overtime compensation for the overtime hours worked This statement reinforces two principles that apply in an overtime workweek (1) only an express or implied contract addressing deductions would authorize an employer to make any deductions that reduce earnings below the regular rate for the straight time hours and (2) the minimum amount that must be paid ldquofree and clearrdquo for the straight time hours may never be less than the highest applicable statutory minimum wage (ldquohellip all the straight time compensation due hellip for the non-overtime hours hellip under any applicable statutehelliprdquo (29 CFR sect778315)) Finally as noted above 29 CFR sect53137(a) authorizes only ldquobona fide deductionsrdquo that ldquoare made for particular items in accordance with the agreement or understanding of the partiesrdquo and declares manipulations that evade statutory overtime requirements to be illegal Accordingly if an employer and an employee have an express or implied agreement over a deduction policy for particular items then bona fide deductions pursuant to the policy will be allowed during overtime workweeks to the extent that they would be allowed in non-overtime workweeks provided that the deductions do not violate other applicable laws the employee receives ldquofree and clearrdquo the highest applicable minimum wage (including prevailing wages) required by any Federal State or local law for the non-overtime hours and the employee receives time-and-one-half the regular rate of pay based on the stipulated wage before any deductions are made for all the overtime hours Where no express or implied agreement exists as to deductions for particular items or if the employer reduces an employeersquos wages for a reason not addressed in the contractual arrangement or for no legitimate reason the deductions are considered illegal and are not allowed during overtime workweeks The following standards must be met Deductions must be for particular items according to an agreement or understanding

between the parties The agreement must be reached before the employee performs the work that becomes subject to the deductions The agreement must be specific concerning the particular items for which the deductions will be made and the employee must know how the amount of the deductions will be determined that are included in the agreement The employee must affirmatively agree or assent to the employerrsquos deduction policy While the employeersquos assent to the policy may be written or unwritten the burden of proof that an employee has agreed to the deduction policy rests on the employer

Only bona fide deductions made for particular items are permitted Deductions which

evade other laws (Federal State or local) or which are otherwise prohibited by other authority are not bona fide (eg if a State law prohibits any deductions from employee wages for tools and similar items or equipment that are business expenses of the employer we would not allow any such deductions in that State in an overtime workweek regardless of whether the highest minimum wage enforced by the Division was paid (net) after the deductions) Deductions for amounts above the reasonable cost to the employer of furnishing a particular item to an

employee are also not bona fide (eg furnishing items to employees ldquoat a profitrdquo) Deductions from wages where no prior agreement exists as to particular items are never permitted in an overtime work week

The regular rate of pay is based on the stipulated wage before any deductions are made

Deductions for non-3(m) items that reduce an employeersquos rate of pay to below the highest applicable legally-required minimum wage are illegal unless the law establishing that minimum wage allows the particular deductions When an employee covered by the overtime requirements works overtime hours deductions may be made according to an agreement that reduce the effective hourly rate down to the highest required minimum wage but only from the non-overtime hours (first 40 hours in the week) and proper time-and-one-half the full regular rate (pre-deductions) must be paid for all statutory overtime hours

The purpose and effect of the deductions are not to evade the overtime requirements or

other laws Deductions made only in overtime workweeks or increases in prices charged during overtime workweeks compared to non-overtime workweeks are considered manipulations to evade statutory overtime requirements which are prohibited Deductions that violate other applicable laws (Federal State or local) are prohibited in an overtime workweek

Various other Federal State and local laws regulate payment of wages prohibit or restrict payment of wages in services or facilities outlaw ldquokickbacksrdquo restrain assignments and otherwise govern the calculation of wages and the frequency and manner of paying them Nothing in the FLSA or other Division-administered statutes regulations or interpretations overrides or nullifies any higher standards or more-stringent provisions of these other laws See 29 CFR sect53126 Accordingly to the extent that the deductions for uniforms and weapons meet the above criteria they would be allowable under the FLSA You also asked whether the cost of pre-employment physicals could be deducted in the same manner It is our position that an employer may not require an employee to pay for the cost of obtaining a physical that is required by the employer for the employee to continue employment if doing so cuts into any statutorily-required minimum wage or overtime premium pay according to the above criteria We also consider the time spent in obtaining such a physical examination as compensable hours of work On the other hand however we would not assert that the cost of the physical or the time spent in obtaining it would have to be borne by a prospective employer if it occurs prior to employment or a commitment to employ the individual We based this opinion exclusively on the facts and circumstances described in your request We are providing it to you on the basis of your representation explicit or implied that you have provided a full and fair description of all the facts and circumstances that would be pertinent to our consideration of the question presented If any other factual or historical background exists that is not contained in your request it might require a different conclusion than the one we have expressed above Sincerely Thomas M Markey Acting Administrator Note The actual name(s) was removed to preserve privacy

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

Fact Sheet 30 The Federal Wage Garnishment Law Consumer Credit Protection Acts Title 3 (CCPA) This fact sheet provides general information concerning the amount that may be withheld from a persons earnings under the CCPA and the laws protection from termination because of garnishment for any single debt What is a wage garnishment A wage garnishment is any legal or equitable procedure through which some portion of a persons earnings is required to be withheld by an employer for the payment of a debt Most garnishments are made by court order Other types of legal or equitable procedures for garnishment include IRS or state tax collection agency levies for unpaid taxes and federal agency administrative garnishments for non-tax debts owed the federal government Wage garnishments do not include voluntary wage assignmentsmdashthat is situations in which employees voluntarily agree that their employers may turn over some specified amount of their earnings to a creditor or creditors

Which federal law regulates wage garnishment

Title III of the Consumer Credit Protection Act limits the amount of an employees earnings that may be garnished and protects an employee from being fired if pay is garnished for only one debt Title III is administered by the Wage and Hour Division of the US Department of Labors Employment Standards Administration The Wage and Hour Division has no other authority with regard to garnishments Questions over issues other than the amount being garnished or termination should be referred to the court or agency initiating the withholding action For example questions regarding the priority given to certain garnishments over others are not matters covered by Title III and may be referred to the court or agency initiating the garnishment action To whom does the law apply The law protects everyone receiving personal earnings ie wages salaries commissions bonuses or other incomemdashincluding earnings from a pension or retirement program Tips are generally not considered earnings for the purposes of the wage garnishment law The law applies in all 50 states the District of Columbia and all US territories and possessions What is the protection against discharge when wages are garnished The CCPA prohibits an employer from firing an employee whose earnings are subject to garnishment for any one debt regardless of the number of levies made or proceedings brought to collect that debt because of the single garnishment The Act does not prohibit discharge because an employees earnings are separately garnished for two or more debts

FS 30

What are the restrictions on wage garnishment The amount of pay subject to garnishment is based on an employees disposable earnings which is the amount left after legally required deductions are made Examples of such deductions include federal state and local taxes the employees share of State Unemployment Insurance and Social Security It also includes withholdings for employee retirement systems required by law Deductions not required by lawmdashsuch as those for voluntary wage assignments union dues health and life insurance contributions to charitable causes purchases of savings bonds retirement plan contributions (except those required by law) and payments to employers for payroll advances or purchases of merchandisemdashusually may not be subtracted from gross earnings when calculating disposable earnings under the CCPA The law sets the maximum amount that may be garnished in any workweek or pay period regardless of the number of garnishment orders received by the employer For ordinary garnishments (ie those not for support bankruptcy or any state or federal tax) the weekly amount may not exceed the lesser of two figures 25 percent of the employees disposable earnings or the amount by which an employees disposable earnings are greater than 30 times the federal minimum wage (currently $725 an hour) For illustration if the pay period is weekly and disposable earnings are $21750 ($725 times 30) or less there can be no garnishment If disposable earnings are more than $21750 but less than $29000 ($725 times 40) the amount above $21750 can be garnished A maximum of 25 percent can be garnished if disposable income earnings are $29000 or more When pay periods cover more than one week multiples of the weekly restrictions must be used to calculate the maximum amounts that may be garnished The table and examples at the end of this fact sheet illustrate these amounts What about child support and alimony Specific restrictions apply to court orders for child support or alimony The garnishment law allows up to 50 percent of a workers disposable earnings to be garnished for these purposes if the worker is supporting another spouse or child or up to 60 percent if the worker is not An additional 5 percent may be garnished for support payments more than 12 weeks in arrears Are there any exceptions to the law The wage garnishment law specifies that the garnishment restrictions do not apply to certain bankruptcy court orders or to debts due for federal or state taxes If a state wage garnishment law differs from the CCPA the law resulting in the smaller garnishment must be observed What about non-tax debts owed federal agencies The Debt Collection Improvement Act authorizes federal agencies or collection agencies under contract with them to garnish up to 15 of disposable earnings to repay defaulted debts owed the US government The Higher Education Act authorizes the Department of Educations guaranty agencies to garnish up to 10 of disposable earnings to repay defaulted federal student loans Such withholding is also subject to the provisions of the federal wage garnishment law but not state garnishment laws Unless the total of all garnishments exceeds 25 of disposable earnings questions regarding such garnishments should be referred to the agency initiating the withholding action

EXAMPLES OF AMOUNTS SUBJECT TO GARNISHMENT BASED ON THE $725 AN HOUR MINIMUM WAGE The following examples illustrate the statutory tests for determining the amounts subject to garnishment

1 An employees gross earnings in a particular week are $26300 After deductions required by law the disposable earnings are $23300 In this week $1550 may be garnished since only the amount over $21750 may be garnished where the disposable earnings are $29000 or less The employee would be paid $21750

2 An employees gross earnings in a particular workweek are $40200 After deductions required by law the disposable earnings are $36800 In this week 25 percent of the disposable earnings may be garnished ($36800 times 25 = $9200) The employee would be paid $27600

3 A garnishment order is received after the second work day of the week It requires a garnishment based on wages earned up to that day be withheld The employee is paid $6000 a day Since less than $21750 has been earned no garnishment is permitted However if another garnishment is received when the workweek is complete or in states where continuing garnishments are issued the employer will withhold on the basis of the earnings for the entire week

4 An employee paid every other week has disposable earnings of $50000 for the first week and $8000 for the second week of the pay period for a total of $58000 In a biweekly pay period when disposable earnings are at or above $58000 for the pay period 25 may be garnished $14500 (25 times $58000) is subject to garnishment It does not matter that the disposable earnings in the second week are less than $21750

5 An employee on a $40000 weekly draw against commissions has disposable earnings each week of $30000 Commissions paid monthly total $300000 for July after deductions required by law Each draw and the balance due at the monthly settlement are separately subject to the laws restrictions Thus 25 of each draw ($7500 in this example) may be garnished At the end of the month the $120000 previously drawn is subtracted from the $300000 settlement figure and 25 of the balance may be garnished In this example the garnishable amount is $45000 ($3000 minus $1200 times 25)

6 Pursuant to a garnishment order (with priority) for child support an employer withholds $9000 a week from the wages of an employee who has disposable earnings of $29500 a week A garnishment order for the collection of a defaulted student loan is also served The limit for normal garnishments of 25 applies to the debt for the outstanding student loan Under the formula for normal garnishments a maximum of $7375 (25 times $29500) is garnishable The $9000 support payments may be withheld because the normal restrictions do not apply to court orders for support No withholding for the defaulted student loan may be made because the amount already withheld is more than the amount that may be withheld for normal garnishments Additional withholdings could be made to collect support delinquent federal or state taxes and certain bankruptcy court ordered payments

MAXIMUM GARNISHMENT OF DISPOSABLE EARNINGS UNDER NORMAL CIRCUMSTANCES

FOR THE $725 MINIMUM WAGE

Weekly Biweekly Semimonthly Monthly

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

More than $21750 but less than $29000 Amount ABOVE

$21750

$43500

More than $47125 but less than $62833

Amount ABOVE $47125

Amount ABOVE $94250

$29000or more MAXIMUM 25

$58000 or more MAXIMUM 25

These restrictions do not apply to garnishments for child andor spousal support bankruptcy or actions to recover state or federal taxes

Where to Obtain Additional Information

For additional information visit our Wage and Hour Division Website httpwwwwagehourdolgov andor call our toll-free information and helpline available 8 am to 5 pm in your time zone 1-866-4-USWAGE (1-866-487-9243) This publication is for general information and is not to be considered in the same light as official statements of position contained in the regulations US Department of Labor Frances Perkins Building 200 Constitution Avenue NW Washington DC 20210

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

Fact Sheet 70 Frequently Asked Questions Regarding Furloughs and Other Reductions in Pay and Hours Worked Issues

The Department of Laborrsquos (DOL) Wage and Hour Division (WHD) is responsible for administering and enforcing some of our nationrsquos most comprehensive labor laws including the minimum wage overtime recordkeeping and youth employment provisions of the Fair Labor Standards Act (FLSA)

The following information is intended to answer some of the most frequently asked questions that have arisen when private and public employers require employees to take furloughs and to take other reductions in pay and or hours worked as businesses and State and local governments adjust to economic challenges

1 If an employer is having trouble meeting payroll do they need to pay non-exemptemployees on the regular payday

In general an employer must pay covered non-exempt employees the full minimum wage and any statutory overtime due on the regularly scheduled pay day for the workweek in question Failure to do so constitutes a violation of the FLSA When the correct amount of overtime compensation cannot be determined until sometime after the regular pay period however the requirements of the FLSA will be satisfied if the employer pays the excess overtime compensation as soon after the regular pay period as is practicable

2 Is it legal for an employer to reduce the wages or number of hours of an hourly employee

The FLSA requires that all covered non-exempt employees receive at least the applicable Federal minimum wage for all hours worked In a week in which employees work overtime they must receive their regular rate of pay and overtime pay at a rate not less than one and one-half times the regular rate of pay for all overtime hours The Act does not preclude an employer from lowering an employeersquos hourly rate provided the rate paid is at least the minimum wage or from reducing the number of hours the employee is scheduled to work

3 Does an employer need to pay an hourly employee for a full day of work if he or she wasscheduled for a full day but only worked a partial day due to lack of work

The FLSA does not require employers to pay non-exempt employees for hours they did not work

4 In general can an employer reduce an otherwise exempt employeersquos salary due to aslowdown in business

Reductions in the predetermined salary of an employee who is exempt under Part 541 of the Department of Laborrsquos regulations will ordinarily cause a loss of the exemption Such an employee

FS 70

The Department announced a Final Rule focused primarily on updating the salary and compensation levels needed for Executive Administrative and Professional workers to be exempt For more information see httpwwwdolgovwhdovertimefinal2016

rclaw

Rectangle

must then be paid the minimum wage and overtime required by the FLSA as discussed in FAQ 2 above In some circumstances however a prospective reduction in salary may not cause a loss of the exemption See FAQ 7 below Section 13(a)(1) of the FLSA exempts from minimum wage and overtime pay ldquoany employee employed in a bona fide executive administrative or professional capacityrdquo as defined in 29 CFR 541 An employee qualifies for exemption if the duties and salary tests are met See Fact Sheet 17A FLSA section 13(a)(1) requires payment of at least $455 per week on a ldquosalaryrdquo basis for those employed as exempt executive administrative or professional employees See Fact Sheet 17G A salary is a predetermined amount constituting all or part of the employeersquos compensation which is not subject to reduction because of variations in the quality or quantity of the work performed An employer must pay an exempt employee the full predetermined salary amount ldquofree and clearrdquo for any week in which the employee performs any work without regard to the number of days or hours worked However there is no requirement that the predetermined salary be paid if the employee performs no work for an entire workweek Deductions may not be made from the employeersquos predetermined salary for absences occasioned by the employer or by the operating requirements of the business If the employee is ready willing and able to work deductions may not be made for time when work is not available Salary deductions are generally not permissible if the employee works less than a full day Except for certain limited exceptions found in 29 CFR 541602(b)(1)-(7) salary deductions result in loss of the section 13(a)(1) exemption Deductions from the pay of an employee of a public agency for absences due to a budget-required furlough disqualify the employee from being paid on a salary basis only in the workweek when the furlough occurs and for which the pay is accordingly reduced under 29 CFR 541710 See FAQ 9 below Physicians lawyers outside salespersons or teachers in bona fide educational institutions are not subject to any salary requirements Deductions from the salary or pay of such employees will not result in loss of the exemption 5 Can an employer reduce the leave of a salaried exempt employee An employer can substitute or reduce an exempt employeersquos accrued leave (or run a negative leave balance) for the time an employee is absent from work even if it is less than a full day and even if the absence is directed by the employer because of lack of work without affecting the salary basis payment provided that the employee still receives payment equal to the employeersquos predetermined salary in any week in which any work is performed even if the employee has no leave remaining 6 Can a salaried exempt employee volunteer to take time off of work due to lack of work If the employer seeks volunteers to take time off due to insufficient work and the exempt employee volunteers to take the day(s) off for personal reasons other than sickness or disability salary deductions may be made for one or more full days of missed work The employeersquos decision must be completely voluntary 7 Can an employer make prospective reduction in pay for a salaried exempt employee due to the economic downturn

An employer is not prohibited from prospectively reducing the predetermined salary amount to be paid regularly to a Part 541 exempt employee during a business or economic slowdown provided the change is bona fide and not used as a device to evade the salary basis requirements Such a predetermined regular salary reduction not related to the quantity or quality of work performed will not result in loss of the exemption as long as the employee still receives on a salary basis at least $455 per week On the other hand deductions from predetermined pay occasioned by day-to-day or week-to-week determinations of the operating requirements of the business constitute impermissible deductions from the predetermined salary and would result in loss of the exemption The difference is that the first instance involves a prospective reduction in the predetermined pay to reflect the long term business needs rather than a short-term day-to-day or week-to-week deduction from the fixed salary for absences from scheduled work occasioned by the employer or its business operations 8 Can an employee still be on-call or performing work at home during a furlough day Whether on-call time is hours worked under the FLSA depends upon the particular circumstances Generally the facts may show that the employee was engaged to wait (which is work time) or the facts may show that the employee was waiting to be engaged (which is not work time) For example a secretary who reads a book while waiting for dictation or a fireman who plays checkers while waiting for an alarm is working during such periods of inactivity These employees have been engaged to wait An employee who is required to remain on call on the employers premises is working while on call An employee who is allowed to leave a message where heshe can be reached is not working (in most cases) while on call Additional constraints on the employees freedom could require this time to be compensated Employees who perform part or all of their normal job duties during a furlough day are working while performing such duties 9 Are the rules for paying furloughed employees different for State and local governments For non-exempt public employees see FAQ 2 For salaried exempt employees in the case of public sector employees a specific rule applies to furloughs as described in the following regulatory text 29 CFR 541710

Deductions from the pay of an employee of a public agency for absences due to a budget-required furlough shall not disqualify the employee from being paid on a salary basis except in the workweek in which the furlough occurs and for which the employees pay is accordingly reduced

10 Does it matter if the State or local government employee is considered an essential or critical employee for the purposes of a required furlough The application of the FLSA is not affected by the classification of an employee as essential or critical for the purposes of a required furlough 11 What remedies are available to correct violations of the FLSA when employees are not paid on a timely basis

a The Secretary of Labor may bring suit for back wages and an equal amount as liquidated damages or for interest on the back wages or the Secretary of Labor may bring suit for an injunction against the failure to pay wages when due

b Employees who have filed complaints or provided information during an investigation are protected under the law They may not be discriminated against or discharged for having done so If they are they may file a suit or the Secretary of Labor may file a suit on their behalf for relief including reinstatement to their jobs and payment of wages lost plus monetary damages

c An employee may file suit to recover back wages and an equal amount in liquidated damages plus attorneyrsquos fees and court costs Please note that the US Supreme Court has ruled that the Eleventh Amendment prohibits employees of State governments from filing such suits against their State employers for monetary relief in federal courts (under Seminole Tribe of Florida v Florida 517 US 44 (1996)) and in State courts unless the State waives its sovereign immunity (under Alden v Maine 527 US 706 (1999))

d Civil money penalties may be assessed for repeat and or willful violations of the FLSArsquos minimum wage or overtime requirements

e Employers willfully violating the law also may face criminal penalties including fines and imprisonment

ADDITIONAL INFORMATION The Wage and Hour Division is available to assist For more information regarding the FLSA visit the WHD Web site at wwwwagehourdolgov or call our toll-free help line available 8 am to 5 pm in your time zone at 1-866-4US-WAGE (1-866-487-9243)

Deductions for the Cost of Training
Seasonal Recreational Employees
Inclement Weather Absences
Is Training Time Paid Work
Travel Time to Training and Conferences
Permissible Deductions for Exempt Employees
Second Job for the Same Employer
New Ovetime Rules
Overtime Pay for Law Enforcement and Firefighting Employees
Fluctuating Work Weeks
Internships under FLSA
DOL Internship Programs 71
DOL Deductions for Uniforms 16
Deductions for Wages Opinion Letter
DOL Garnishment Law 30
DOL Furloughs 70

Page 2: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

beginning employment which the city could do by hiring only individuals already possessing law enforcement certification Instead the city elected to make what was essentially a loan to police officer trainees of the cost of their police academy training In this case the conditional offer the plaintiff signed explained that the city would forgive her repayment obligation at a specified rate and that she would owe nothing after five years of service Because the plaintiff chose not to serve the five years necessary to secure complete loan forgiveness the city was the plaintiffrsquos creditor Because it satisfied the FLSArsquos requirements by paying her at least minimum wage for her final week of work it did not violate the law

Conclusion

Based on the Heder and Gordon decisions it appears that the deduction of the cost of an employeersquos training from his or her paychecks is permissible so long as employees are advised of the policy at the outset of employment and the deduction does not bring the employeersquos regular rate of pay below minimum wage

For more on deductions from employee wages see Bob Joycersquos January 4 2011 post Public Employer Withholding from Last Paycheck at httpcanonssoguncedup=3750

Links

wwwdolgovwhdopinionFLSANA20042004_10_08_19FLSA_NA_recouppdflawresourceorgpubuscasereporterF3295295F3d77701-4118htmlcasetextcomcasegordon-v-city-of-oakland-2

Page 2

httpcanonssoguncedu

Page 2

By Diane Juffras

Page

Conclusion

Links

Page

By Diane Juffras

Nonexempt Employees

Exempt Employees

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Page 3

httpcanonssoguncedu

Page 3

Links

Page 4

httpcanonssoguncedu

Page 4

By Diane Juffras

Background

The General Rule

Page

Links

Page

By Diane Juffras

Travel Time Rules

Page

a regular workday

Why the difference

Links

Page

By Diane Juffras

Page

Links

Page

By Diane Juffras

Background

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

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Rectangle

New Ovetime Rules
DOL Furloughs 70

By Diane Juffras

Page

Conclusion

Links

Page

By Diane Juffras

Nonexempt Employees

Exempt Employees

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Page 3

httpcanonssoguncedu

Page 3

Links

Page 4

httpcanonssoguncedu

Page 4

By Diane Juffras

Background

The General Rule

Page

Links

Page

By Diane Juffras

Travel Time Rules

Page

a regular workday

Why the difference

Links

Page

By Diane Juffras

Page

Links

Page

By Diane Juffras

Background

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 4: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

Conclusion

Links

Page

By Diane Juffras

Nonexempt Employees

Exempt Employees

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Page 3

httpcanonssoguncedu

Page 3

Links

Page 4

httpcanonssoguncedu

Page 4

By Diane Juffras

Background

The General Rule

Page

Links

Page

By Diane Juffras

Travel Time Rules

Page

a regular workday

Why the difference

Links

Page

By Diane Juffras

Page

Links

Page

By Diane Juffras

Background

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 5: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

By Diane Juffras

Nonexempt Employees

Exempt Employees

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Page 3

httpcanonssoguncedu

Page 3

Links

Page 4

httpcanonssoguncedu

Page 4

By Diane Juffras

Background

The General Rule

Page

Links

Page

By Diane Juffras

Travel Time Rules

Page

a regular workday

Why the difference

Links

Page

By Diane Juffras

Page

Links

Page

By Diane Juffras

Background

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 6: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

Page 2

httpcanonssoguncedu

Page 2

Page 3

httpcanonssoguncedu

Page 3

Links

Page 4

httpcanonssoguncedu

Page 4

By Diane Juffras

Background

The General Rule

Page

Links

Page

By Diane Juffras

Travel Time Rules

Page

a regular workday

Why the difference

Links

Page

By Diane Juffras

Page

Links

Page

By Diane Juffras

Background

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 7: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

Page 3

httpcanonssoguncedu

Page 3

Links

Page 4

httpcanonssoguncedu

Page 4

By Diane Juffras

Background

The General Rule

Page

Links

Page

By Diane Juffras

Travel Time Rules

Page

a regular workday

Why the difference

Links

Page

By Diane Juffras

Page

Links

Page

By Diane Juffras

Background

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 8: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

Links

Page 4

httpcanonssoguncedu

Page 4

By Diane Juffras

Background

The General Rule

Page

Links

Page

By Diane Juffras

Travel Time Rules

Page

a regular workday

Why the difference

Links

Page

By Diane Juffras

Page

Links

Page

By Diane Juffras

Background

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 9: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

By Diane Juffras

Background

The General Rule

Page

Links

Page

By Diane Juffras

Travel Time Rules

Page

a regular workday

Why the difference

Links

Page

By Diane Juffras

Page

Links

Page

By Diane Juffras

Background

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page

Links

Page

By Diane Juffras

Travel Time Rules

Page

a regular workday

Why the difference

Links

Page

By Diane Juffras

Page

Links

Page

By Diane Juffras

Background

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Links

Page

By Diane Juffras

Travel Time Rules

Page

a regular workday

Why the difference

Links

Page

By Diane Juffras

Page

Links

Page

By Diane Juffras

Background

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page

By Diane Juffras

Travel Time Rules

Page

a regular workday

Why the difference

Links

Page

By Diane Juffras

Page

Links

Page

By Diane Juffras

Background

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 13: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

By Diane Juffras

Travel Time Rules

Page

a regular workday

Why the difference

Links

Page

By Diane Juffras

Page

Links

Page

By Diane Juffras

Background

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 14: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

a regular workday

Why the difference

Links

Page

By Diane Juffras

Page

Links

Page

By Diane Juffras

Background

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

By Diane Juffras

Page

Links

Page

By Diane Juffras

Background

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Links

Page

By Diane Juffras

Background

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 17: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

By Diane Juffras

Background

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 20: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 21: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

By Diane Juffras

Background

Some History

Page

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 22: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

The Final Rule

he 40th

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 26: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 27: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

By Diane Juffras

Background

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 29: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

Citations

Links

Page

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 30: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 31: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

By Diane Juffras

Background

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 32: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 33: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 34: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 35: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

By Diane Juffras

Page 1

httpcanonssoguncedu

Page 1

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 36: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

Page 2

httpcanonssoguncedu

Page 2

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 37: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

Conclusion

Links

Page 3

httpcanonssoguncedu

Page 3

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 38: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 39: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

(April 2010)

internship

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 40: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 41: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

(Revised July 2009)

FS 16

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 42: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 43: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

February 16 2001

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 44: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 45: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 46: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13 13

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 47: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

(Revised July 2009)

FS 30

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 48: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 49: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 50: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

$21750 or less NONE

$43500 or less NONE

$47125 or less NONE

$94250 or less NONE

$21750

$43500

Amount ABOVE $47125

Amount ABOVE $94250

1-866-4-USWAGE TTY 1-866-487-9243

Contact Us

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 51: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

November 2009

FS 70

rclaw

Rectangle

New Ovetime Rules
DOL Furloughs 70

Page 52: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

New Ovetime Rules
DOL Furloughs 70

Page 53: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

New Ovetime Rules
DOL Furloughs 70

Page 54: Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before completing three years of service. The Seventh Circuit upheld the reimbursement agreement,

New Ovetime Rules
DOL Furloughs 70

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Coates' Canons Blog: Deductions for the Cost of Training under … · firefighter left before...

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