On July 1, 2015, I informed you that the Department of Labor was initiating a change to the white collar exemption regulations and beginning a public comment period. As the DoL reviews tens of thousands of comments on its proposed changes to the White Collar Exemptions, employers should begin analyzing their exempt positions to determine whether they will still be exempt from overtime after the rule is inevitably issued. I believe that even after the review of the public comments, the DoL will not alter its course much, if at all. The changes are believed to be happening in the Summer of 2016, but they could arrive as early as the first quarter of 2016.
This is also a great time to review your job descriptions for Americans with Disabilities Act and other compliance issues. If you have questions about your analyses and revisions, please feel free to contact me.