© 2024 Seyfarth Shaw LLP | www.seyfarth.com Classification Guidebook | 31 Sample Announcements and Communications A. Communication Plan Checklist Regardless of the exact plan for the communication announcing coming changes, we suggest that the employer make sure to include the following high-level items: Internal initial announcements for affected employees and managers List of likely questions from affected employees and others Immediate response scripts (generalized in nature, as placeholders until more targeted and level-specific scripts are drafted/approved) Comprehensive set of response scripts by level (using internal interviews, FAQs, etc.) Completed script folders Embed scripts into training While each employer and set of changes is unique and warrants a tailored approach, below is a suggested outline for some of what a change communication may cover: Make certain that “immediate responses” are available that can be utilized to safely respond to the most basic anticipated questions. Without hinting any political biases, explain that the U.S. Department of Labor recently enacted new rules for determining whether an employee is exempt from (or ineligible for) overtime pay. You might even note that a stated goal of the new rules is to make more employees non-exempt (or overtime eligible). Explain that there are several different exemptions, each of which has its own separate set of requirements, and that the various exemption rules do not always make practical or logical sense to most business people. Even companies with sophisticated in-house legal and HR departments may require the assistance of a lawyer who specializes in wage-and-hour law to interpret the murky and various overtime exemption rules. Explain that compliance with the rules is mandatory and that the DOL is requiring companies to make changes rather quickly to come into compliance. It is because of the government’s timeline, not any sense of urgency on the part of the employer, that the changes previewed today must be finalized and implemented quickly. Notify the employees that, at a minimum, the DOL’s new rule will require changes to the amount of base compensation that certain employees receive, the form of compensation that they receive (i.e., salary, an hourly rate, commissions, or some other method of pay), and their eligibility for overtime pay if they work more than 40 hours in a week.
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