Remember the proposed change in Department of Labor (DOL) overtime rules that we were all preparing to implement last year? And how it was blocked at the last minute by the courts? Well, DOL is now revisiting the issue and soliciting public comments regarding the rules. We encourage nonprofits to submit comments so the rules will be made with nonprofits in mind, not just private companies. Let them know how changes will impact your ability to deliver on your mission by sharing how an increase in the minimum salary levels would affect operations, resources, and staffing, as well as what impact the changed regulations would have on the people relying on the services and the mission of the nonprofit.
If you receive government contracts, you may wish to comment on the bind nonprofits are put in when new regulations drive up costs but there is no commensurate increase in reimbursement rates during the contract period. Do you know that federal for-profit contractors are entitled to seek “labor standards adjustments” or “equitable adjustments” to protect them from government-mandated labor cost increases, but that right is currently not available to nonprofits performing work under government grants? We encourage nonprofits receiving government grants to comment on this issue and request equal treatment!
The National Council of Nonprofits has prepared excellent analysis of the issue and some things to consider prior to submitting comments: Labor Department Reopens White-Collar Salary Exemption for Comments. The deadline for submitting comments to the Department of Labor is September 25, 2017. Washington Nonprofits will be submitting comments with our members in mind, but please join us. And please let us know that you have taken this action!