Dear Washington Nonprofits Members,
I wanted to be sure you knew that the U.S. Department of Labor has an open request for information (RFI) on updating the rules for overtime pay. A quick review of the comments submitted so far reveals that less than 100 of the 138,000 comments reference nonprofits. Please participate so that nonprofit voices are heard.
Despite a federal judge formally rejecting the Obama Administration’s proposed changes to overtime rules, the Trump Administration is still soliciting feedback from employers on how best to update the overtime rules. We request that your organization respond to the RFI by following these steps:
- Conduct a mission-based analysis of what the RFI’s questions mean for your organization. You can review the National Council of Nonprofits’ analysis, which translates the questions into plain English beginning on page 5.
- Submit a formal public comment to the RFI here and email a copy of your comments to the Small Business Administration’s Office of Advocacy at Janis.Reyes@sba.gov before the September 25th deadline.
Even if your organization does not have time to submit detailed comments, consider submitting something short that conveys one or two key points, such as:
- Updated overtime standards should apply to all employers, so that nonprofits are not disadvantaged in the labor market.
- Any formula used to update overtime pay standards should be predictable so that your agency can accurately forecast its personnel costs.
- Publicly-funded contracts should be updated to reflect increases in personnel costs.
- The Department of Labor should provide clear, explicit guidance on updated overtime standards in order to avoid ambiguity and confusion among employers.
Please contact our Director of Public Policy and Advocacy David Streeter at email@example.com once you submit a comment or if you have questions.