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COSIDA CONFERENCE CALLSeptember 15, 2016Tracy WarrenCLARK TEUSCHER: Welcome to the second installment of the 2016-2017 CoSIDA Continuing Education Series, sponsored once again by Capital One. My name is Clark Teuscher. I'm the Sports Information Director at North Central College and the co-chair for the CoSIDA Continuing Education Committee. Attendees for today's presentation are invited to submit questions in the chat window while following along. We'll work as many of those questions into the discussion as we can today. The webinar is being recorded and will be made available, along with a full FastScript from CoSIDA's official transcript provider, ASAP Sports, for on-demand use exclusively at CoSIDA Connect. With that, we will turn things over to Tracy Warren. Tracy? TRACY WARREN: Thank you very much. Hello everyone. It's great to be before you today. I saw and spoke with many of you in Dallas regarding this very subject of the Fair Labor Standard Act and its impact on sports information directors and departments. You're probably already seeing the changing landscape with the beginning of the school year. Many coach are already getting reclassified. Budgets are being redone. We are kind of wondering what's going to happen to the sports information director. So I'll go through some of these PowerPoint slides. Also going to answer some questions and going to address things like what are exempt, nonexempt, what can we expect in terms of the pay? What do we did with travel time for sports information directors? How about waiting time or on-call time? Is that compensable time for sports information directors? Maybe what are some solutions to approach our athletic director or our in-house counsel for the universities as it relates to the sports information director. Feel free to submit additional questions. My contact information will also be included. So if we don't get to your question today, certainly feel free to send me questions after the presentation. I'm going to go ahead and advance the slide. So the playing field is this: Universities are changing the status of coaches right now, but not sports information directors in anticipation of the December 2016 implementation of the final rule. What we're seeing is there has been some guidance as to how coaches can qualify as exempt employees, but not sports information directors. We're looking at athletic department audits. They're underway, and they have been since this ruling kind of came down in the spring. They're kind of classifying and categorizing budgets for sports information directors as well as coaches and athletic trainers as a result of the new Department of Labor regulations. We're going to look at some risks posed to sports information directors and their departments by these regulations and I'll answer some questions. Here is what we're seeing. The Fair Labor Standard Act is the federal law which governs wages and hours and working conditions and the payments of that throughout the country. There is also state law which could be more strenuous than the federal law. When looking at the amount of litigation which has increased under the FLSA, and it has escalated, and I anticipate in 2016-2017, with these Department of Labor regulation changes set to hit, that the amount of litigation is only going to increase. Quite frankly folks, athletic directors aren't well versed in what is a compensable hour and what is overtime. They are just concerned about keeping budgets. Oftentimes it's the sports information director that has to ask for education either from the in-house counsel or providing it on their on. Here is what the Fair Labor Standard Act says: Jobs are classified as either exempt or nonexempt. Exempt means the position does not require overtime pay. Very few of you sports information directors are exempt. Nonexempt means the position requires over time pay for over 40 hours in a week which requires accurate record keeping. Most of that, folks, falls on you, the sports information director. So there are several classic positions or categories. There is the executive exemption, the administrative exemption, and the professional exemption. We call it the EAP exemptions. The professional exemptions are your lawyers, your doctors, and your teachers. That is something that the sports information director cannot classify in. The executive or administrative exemption, typically the executive exemption requires managerial duties. So those that manage a big department could fall under the executive exemption. The administrative exemption says, I do nonmanual work and I exercise discretion and independent judgment. While often many of the sports information directors feel like their job requires discretion and independent judgment, federal and state law says differently. It says simply covering a game or simply preparing things for the web or dialog is not enough to rise to the level of an exemption. Earlier Brian Laubscher from Washington and Lee did a study to examine the role of sports information directors, and it looks like you're required to spend more hours, more travel, and more categories of tasks. And when I looked at this study and I realized how much you folks are doing, I wonder how much of this you would have advanced to both your in-house counsel and your athletic director. I encourage you to go ahead and educate both of them at the same time on the same email about all the things that you do. This study basically looked at all the tasks and then quantified how much time was spent based upon surveys that you folks had responded to of what you're doing. Why that's valuable is that if your counsel is going to do an audit to basically pay you for all your overtime, they need to have an idea of what you're doing when and how long it actually takes. You can't start from, I'm going to pay you a certain amount and you've got to fit everything into that dollar amount. It just doesn't work that way. Yet that's the way we're seeing most athletic directors approach the role of the sports information director. So the greatest time investment by the study, responding to requests for information. Look, you're on call all the time. Game management. You update the website. Layout and design work, and you're doing game notes and press releases, which right now in the fall season could change daily or weekly. While collar exemptions have two main components. To be an exempt employee, folks, you can't fill one of these and not the other. You have to fill both. So you have to make right now at least a salary of $23,663. That's on the federal level. And you have to satisfy the job duty test. That's the EAP test for executive, administrative, or professional. There are no duties changes that coming up for the December 1 Department of Labor changes; however, there is a salary change which is causing a lot of this commotion. For the while collar exemptions, the annualized salary is going to be $47,476 yearly or $913 per week. Now, what we're finding is that athletic directors are now having to change their budgets for those sports information directors that fall under this exempt category. So they're having to actually double the amount they paid exempt sports information directors. It's about time, right? But what they're also trying to do is then minimize the hours worked by the nonexempt employees so they can make up the money that they're having to pay the exempt sports information director. Many of you are subject to multiple hourly rates. There is the federal rate right now which is $7.25. I am in the San Diego City right now. We have our on ordinance, which is $10.50 per hours, and California State is different than the city as well. It's $10 per hour. What we'll see is all of them are going to increase, at least the state and the city, in the state of California 1/20/17. So what has to happen is an exempt pay increase has to follow the stricter standard. Let's say there is someone at San Diego State and they're within the City of San Diego. While the federal level is $47,476, the City of San Diego with its rise in minute wage through the ordinance, it's going to go to $47,840. So San Diego State is going have to pay te exempt employee at least $47,840, the stricter standard that the employer has to follow. So the salary level for the exempt position will update every three years. So it's estimated to be $51,168 in 2020. Employers will be able to make up 10% of the salary threshold for exempt employees by way nondiscretionary bonuses, incentive pay, or commission. So if you're not getting paid $47,476 but you're getting paid $45,000, you may see a bump in your pay every quarter as a nondiscretionary bonus. In other words, you have to hit certain objective Metrix. I've showed up for five games. Okay, you get an additional $1000. I did five websites. Okay, you get an additional $5,000. You have to see these catch-up payments quarterly so that gets the exempt employee to a $47,476 threshold. The compliance deadline is coming up. It's just a couple months away. What I've been seeing on the university level is we're having a lot of discussion about audits which have started to take place over the summer, and already the changes have been made. I'm getting many coaches contacting me saying they're not happy being labeled exempt because now the Department of Labor regulations has given some wiggle room for these coaches who feel like they're in the same basket as you guys. We're there hours at a time and you're only going to pay us $47,476? We're not going to get paid for any overtime or travel or waiting time? The university's response is no. You're going to make $47,476 and that's going to take effect now or at the latest December 1st. So what we're seeing is a lot of the athletic departments, like Arkansas State going to cut. They are going to cut salaries and they're going to shift. We're seeing this. They're shifting a lot of individuals or reducing the size of the department because they're saying the budgets can't operate within the confines of these new Department of Labor regulations. They just don't have it. So the impact has had a very high cost to the number of people within the department. Western Carolina. They also have estimated that their department had 68 full-time employees; 55 of whom had been exempt. They're going to have to make firings because of the increased cost. And he says they are not the only ones. We can tell you from audits and from counsel that we have been providing, this has hit many, many if not all, university athletic departments. So a Labor Department document addressing the new rules and its impact on higher education says, Coaches may be exempt regardless of salary if their primary duty is teaching, which may include instructing athletes in how to perform the sport and/or designing instructional programs for individually student-athletes, for the team as a whole. I have a question here that an individual had written in prior to this presentation. It went like this: We came to the conclusion through legal advice and interpretation that all coaches, regardless of part-time, full time, are exempt under the teaching exemption because they are imparting knowledge, providing feedback, and assessing skills, similar to a full-time or adjunct part-time professor. What have you heard about this approach? I find that the overwhelming majority of the campuses in the U.S. are taking this approach. Any time you say all teachers or all coaches are exempt - all coaches in this case - you have to be careful. You have to take a look at the duties of each coach. You can't assume that all coaches are instructing. You can't assume that all coaches are imparting knowledge. There are many of them that are just recruiting. Others of them are in strength and conditioning. I caution you as a practitioner in this area to say all are doing the same type of work, therefore they are all exempt. You have to take a look at their individual duties. What I am finding is universities are artificially subscribing instructing duties to coaches who perhaps might not otherwise have them to be able to call them exempt employees. So if their job description was a nonteaching or noninstructing position in 2015, you can bet in December 2016 they're going to have some teaching component to it in order to get them labeled exempt. Coaches may also qualify for the academic administrator exemption if their primary duty consists of academic advising to players or responsibility for administration of an academic department. So long as they also receive a salary equal to or minute to teachers at their particular institution. Other exemptions may apply to coaches or athletic trainers with managerial or supervisory responsibility, and discretion to make meaningful decisions independently, but only for positions paid salaries above the new threshold. There is a combined duties test that oftentimes we can look at several buckets of what an individual is doing to get them over and above and into that exempt status. Only if their salary satisfies the new threshold. If there are so the wiggle room for sports information directors in the future, I think taking a look at what the coaches are doing to be labeled exempt. As I cautioned folks in December, if you're going to go ahead and want the exemption, many SIDs will wind up making the minimum, $47,476, and therefore are not getting compensated for all the overtime and travel time that you're putting into the job today. There is a teaching component that many of you do because you're out there teaching athletes how to appear before the media. You are training many people in your department. So there is some parallel here to what the coaches are doing to get shoehorned into the exemption. It's something we can certainly consider and think about. What I'm asking many sports information directors to do or those in the sports information department, is conduct your own audit or request university counsel to conduct an audit of your sports information department. You would want to bring this to the attention at the same time to the athletic director. They're going to think you're going over their head. Why you're directing university counsel is because the Fair Labor Standard Act is very complex and there is no one right answer. It takes a critical analysis and an audit much like was done by Brian Laubscher at Washington and Lee to determine what duties you do, the time spent, and how much money you should actually be earning if you were compensated for everything that you have a right to be compensated for. I'm asking you to do that, because university counsel oftentimes has so many responsibilities that oftentimes they don't take a closer look unless a fire is hot. That means litigation. So if you proactively say, Hey, can you please conduct an audit of our sports information department? I've given you some first steps on how to that. Here at the ten people in our department. Here is what they are doing. He is what we're asked to do. Here are the sports we're covering. Here are the days that we're working. Here is the time period during the year of which we're working. Here is the amount of money we should be compensated. Here is how much we're not being compensated for. I see this as a problem. I'm a team player. I am bringing it to your attention. That serves two purposes: One, you now have become a whistleblower of sorts. You have said, I'm not being compensated or my department isn't being compensated for all the hours we have been paid. [Sic] I'm trying to help the university by bringing this claim to your attention rather than filing a lawsuit. If they retaliate against you, if the athletic director retaliates against you, you have got a whistleblower claim because you raised the issue of not being paid either overtime, travel time, waiting time, on call time. All these things you're asked to do. Or telecommuting time. These are all things you've been asked to do, yet you're not sure if you've been compensated for it. So your audit would be look at your duties, your time spent, estimate the hours spent, estimate the annual cost for your team, and provide options for cost cutting. Why? They'll do it for you. Why not be proactive and give them some solutions and continue to work with the team where you can. If costs are cut, you then provide an impact analysis on the sports coverage. Okay, you want me to get rid of three people in my department. Fine. We're not going to be able to get football covered from these hours to these hours. We're not going to be able to do the Frozen Four with four people. We'll have to do them with one. If we only do it with one, only this amount of coverage is going to come out of one person. And by the way, that's going to cost significant overtime, unless that person is exempt. When you show the negative results of the cost cutting, and that's typically the impact of the coverage of your sports, then it crystallizes it for both of athletic director and the university counsel that they have to do some shuffling. So you've got to get a lot of people involved in this. It's legal. It's your athletic director. It's your SID. And they're necessary to identify the solutions both legally and financially, and then you and your department have to live with it. So here is the big picture. There are various options for compliance with the new rules. It looks like this: Going to be increases for salary $47,476. Employees are probably already being reclassified; jobs are being restructured. Some folks are taking on more duties than they probably would've in the past. We are looking at a decrease in workforce or compression of salaries or wages to catch up to the exempt. We're looking at how operations are impacted. Model the cost of reclassification, identify the number of hours impacted, and the employees. Explore some of the following. So to accurately record time, which we find SIDs don't do very well because you are just always the clock. Maybe you swipe -- you do time proxy. Swipe cards, have records, something. Do a hand scan. I have a lit of clients that do hand scanning. I go in, as soon I go to my computer I hand scan. I'm on the clock. As soon as I leave my computer I am off the clock. Now if I go and I'm traveling somewhere, I may be on the clock. So you have to accurately capture all the time you spend working. What I find is SIDs don't know if what they're doing is compensable work. I think that warrants perhaps another presentation, because a lot of things you're doing, folks, you should be paid for. Travel time compensation requirements are complex. It involves careful attention to commuting time, work-hour travel and out-of-town travel for an overnight trip. This is where I should probably address some of the questions about travel time. We've gotten a few questions about travel time. Going to generally answer them, and then if you folks have follow up we can certainly follow up offline. So there are different principles that apply. If you're traveling from before a regular workday and you return to your home, that is not compensable work time. Okay? But if you regularly work at a fixed location in one city. Say you're in South Bend, Indiana and you're going to another city and returning home the same day. Say Notre Dame plays Michigan State this weekend. Let's say you were at Michigan State, you're leaving East Lansing and traveling to South Bend, Indiana. That time is compensable time. If you take your own car, those are expenses that should be paid to you. So the time that you go from your house to South Bend, Indiana from East Lansing is compensable time. Your employer can back out the travel time that it would take for you to get from your house to East Lansing. So if you go to East Lansing every day it's ten minutes. Okay. My employer can then back out the ten minutes when I travel from East Lansing to South Bend. But that travel time is compensable. Time spend by you as part of the activity from site to site to site, that is hours worked. Let's say you're required to go from your house to a news station and then to the university and then go out and cover some folks who are 50 miles off site. That's all compensable travel time. You should be paid for that travel time. If it's overnight, travel from home, away from home overnight, when it cuts across your workday, that's compensable work time. We have to look at that as where you are traveling to and from and how long you were traveling. If you're on an airplane and traveling from East Lansing to South Bend, that time should be paid. So we have to count that as part of our overtime. Again, to reset the scenario: If I start in East Lansing and I get in a plane and travel to South Bend, all the while I'm in that airplane, that's compensable work time. Then I cover the game. Compensable work time. Then I am waiting for players to come to me som I can interview them. Compensable work time. Then you're waiting for folks to get into the bus to go back to East Lansing. That's is compensable work time. Likely you're doing work while you're waiting. If not, we can talk about that scenario. Then you're flying back. Compensable work time. So your day typically may be 12 to 15 hours compensable work time. We talked about the salary increase. You guys all have heard ever $47,476; the wage compression issues are definitely a factor. What I mean by that is a lot of folks who are making $45,000 right now are going to see that folks are going to surpass them because they're exempt employees, and under the new Department of Labor regulations they're required to make at least $47,476. So a lot of people now in the athletic department or in the university may be in that band of $45,000 to a $55,000 wage earners due to the new Department of Labor regulations. Okay, here is the reclassification that we're seeing. Employees' an hourly rate equal to their salary before reclassification. This is going to increase labor costs and may incentivize off-the-clock work and it may lead to wage compression. It looks like this: The sports information director is currently classified as exempt and it earns $37,000 per year. That certainly right now is permissible up until December 1. This breaks down to $711.54 a week. A straight conversion for a 40-hour work week is that SID is making $17.79. So any over time would be at $26.69. So you're paying the SID what you would pay them as an hourly rate, $17.79, and then you pay them the $26.69 for any overtime. So that's one option. Option two: You adjust the salary to reallocate it between the regular wages and overtime. The hourly rate can't fall below the highest applicable minimum wage. Remember the example I showed you of San Diego, California, and Federal? So you've got to hit whatever the highest applicable minimum wage, and in that scenario it was San Diego City wage. In other words, your salary maybe be lower to account for overtime costs. Here is what the example looks like. Same employee working at $37.000 per year, $711.54 a week, based on the study that you've done, you determine that you're working 45 hours per week. You paid the reclassified employee $15 an hour. So you look at $600 a week at the regular rate. That's 40 hours times $15 an hour and then plus $122.50 a week over time. That's five hours of overtime at 15 times time and a half, so you're getting the $712.50 week total earnings. What's happening is they're starting with a number and then figuring out, okay, here is what your hours are. Then they're making this fit in the jigsaw puzzle. Oftentimes what we're finding is it may limit you to that amount of overtime, and I don't that's realistic based on the expectations of your jobs. So reclassifying employees and continue to play a salary plus overtime for hours worked in excess of 40 hours a week. The law doesn't require nonexempt employees be paid on an hourly basis. You can certainly be paid on a salary basis. You still have to keep track of your hours and keep track of your breaks. Why you have to do that is because if you're paid on a salary, you're essentially taking the wage, a fixed salary of say $41,600 a year or $800 a week, and monetize it. What is your hourly rate? So if you're paid a certain salary, any overtime that you're going to make is going to be paid at hourly plus time and a half. So if your regular rate is $20, overtime will be paid at $30. You've got to track how much overtime, even if you're a salaried employee. Salary not mean exempt. Here is the other option we're seeing. It is the fluctuating work week method. This seems to be really taking off, especially with sports information directors and in the university settings. It permits employers to pay nonexempt employees a fixed salary where the employee's hours fluctuate from week to week. That happens for all of you folks. In the summers you maybe a lot slower. Then in the fall and winter you're extremely busy. If your teams make it to the post season you get even busier. So the big benefit of fluctuating work week is that employers need only pay employees an additional .5 multiplier rather than the standard 1.5 for overtime hours. So you have to tell the employees. If you're on a fluctuating work week, you should've been told that the fixed salary is compensation for all hours worked each work week, whatever that number is. So if you're working five hours or of you're working 40 hours, you're being paid on a fluctuating work week. Any overtime would be .5. We do not like this method for California and Pennsylvania because it may be beyond state law. So for those states we don't advise it. Other states we're certainly seeing them use the fluctuating work week. Here is what happens for part-timers. The SID is told that the fixed salary is compensation for the hours worked each work week, whatever their number, and the SID who sees a salary enough to ensure that the fluctuating work week earns more than the minimum wage. If you're in federal law, $7.25; state law, whatever your state law mi is, you have to hit that higher standard even if you're paid on a fluctuating work week and monetize that out. So say $7.25 times 40 hours a week, and then you do the math or we do it times 2080, and you make sure you're being paid at least a minimum wage throughout the duration of the year. Make sure you're tracking hours for reclassified fluctuating work employees, and make sure you're paying overtime if the SID exceeds 40 hours a week. Make sure they never work more than 40 hours a week. That way they get no overtime. Only 25 to 30 hours a week and never 40. That way they get no overtime. Unfortunately we're seeing a lot of universities think about outsourcing. In other words, they're using co-ops to outsource their SID function or hiring new part-time employees. They're converting part-time to full-time and capping their hours. They're redistributing workloads, or, again, outsourcing work. These are some of the shifts we're seeing as the Department of Labor regulations get closer. I put bullying on here because I see this happening with SIDs who approach oftentimes superiors about them not getting paid for hours worked, or they're told to cut their hours because the budget can't handle the amount of hours they're working. So just know that there is some legal protection if you do go to your athletic director who's not receptive and instead responds to you in a bullying or intimidating way. There are some legal protections. That is also the whistleblower. You're covered under statute or common law, and the University or college is covered under the stature of common law. If you report that you're not paid overtime or retaliated against, you're covered. Now you've given your boss knowledge that they're not paying you. Once they have that knowledge, and if there is a change in your terms or conditions of employment, then essentially there is some liability for that university. That is the retaliation. You have high work performance ratings prior to engaging in protected activity, and then low ratings or problems thereafter. Look at the manner in which the sports information director was informed of his or her transfer or termination. Suddenly you're transferred. If there is an inadequate investigation of the charge against the SID, if you report that your athletic director has taken steps against you or counsel hasn't handled it right, look who conducts the investigation. Typically if you're reporting discrimination or harassment, an investigation is required by law. Look who conducts it. Look how it's conducted. See if it's thoroughly conducted. Look at any discipline or transfer that happens after you complain about the protected activity. These are all signs that are there to protect you, but also your university counsel is typically sensitized to this. So they step in and they should be taking proactive steps to make sure, one, you're compensated, and, two, you are not retaliated against for reporting this. We are at about 11:36, and I think I've answered your questions, but I am certainly happy to take some additional questions. THE MODERATOR: Yes, Tracy, we do have several questions from the membership. First op, what is the lowest number of supervised employees that you've seen someone qualify for the administrative exemption. We have someone asking the question that said they have been told they fall under that exemption even though they supervise only two people. Is that a possibility? TRACY WARREN: Yes, that absolutely is a possibility. The administrative exemption usually isn't the supervisory one. That's the executive. The administrative exemption says you exercise discretion and independent judgment, so two people would certainly qualify. CLARK TEUSCHER: Another question here about is there a certain amount of lead time employers are required to give employees before that December 1st deadline? TRACY WARREN: All these changes have to come into effect by that payroll of December 1st. So we're saying by October 1. So within two weeks you folks should have been notified that there are some changes occurring within your department. If not, I would use this seminar as a way to float an email to both your in-house counsel as well as your athletic director to say, Hey, I just went through this FLSA webinar that was given by CoSIDA, and they talked about these changes that are coming down the pike. We should have these changes in place within two weeks. Are we doing anything? CLARK TEUSCHER: For any SIDs who might have their positions eliminated as a result of these changes, what are their legal options? TRACY WARREN: That's a tough one because what the justification is going to be is it's layoffs due to financial restructuring due to the Department of Labor regulations. I don't know that there is a whole lot an SID who is laid off or terminated as a result of this restructuring can do. Unless there was some retaliatory activity, you proactively brought it to your athletic director and then you were the first one terminated, there is not a whole lot you can do. It's required by law, and kudos to the athletic director and university counsel. They're complying with the law. Then you just have to wait for the passage of time to see if the SID department can survive with all the cutbacks. It's the trial and error right now. There's not much, unfortunately. CLARK TEUSCHER: Many times throughout the year sports information directors are put in positions to have to manage events or cover events that occur during times when their institutions are closed and have no office hours. Are those counted as overtime hours even if they fall into the traditional workday? TRACY WARREN: Absolutely. If you're out working or covering an event, irrespective of if the university is open or closed, that's compensable work time. CLARK TEUSCHER: Okay. And in terms of how athletic departments, how private institutions are reacting to these changes, how wide ranging are their reactions to all this? Are the majority of them following a specific model, one of the ones you referenced, or has it been all over the board? TRACY WARREN: It really depends on the athletic department. What I have seen, you know, it's size, right? The bigger universities may be able to handle the Department of Labor regulation change without any increase or decrease in personnel. The smaller departments, I've worked with a couple of you that are one- or two-man or women shows within your department. Those are the ones where impacted the most. Really what we're seeing is what I had suggested here in the webinar. Many people have conducted an audit or asked for the buy-in of the SID of what exactly they're doing so they can monetize and quantify what is compensable time and make sure they're not running any risk of liability. So if anything, the heightened standard, there is no one uniform approach. It really varies from university to university, and quite frankly state to state. CLARK TEUSCHER: For the full time positions that will have capped hours, for those who are having to go that route, what are their options in terms of for sometimes the small one-person shops who will work quite a bit of time outside of office hours. If office hours are capped, what are the options when the questions come about why things aren't getting done? TRACY WARREN: Yeah, and this is kind of the downfall. We're seeing the negative impact analysis. If you're talking about the exempt employee who is being paid $47,476, and he or she is a one-person shop. You're going to see that part of the downfall is this person can't do everything, and you're going to see burnout happen a lot quicker. A human being can only do so much. I would manage the expectations of your athletic director and get in some dialog and say, Look, these are all the things I'm doing. I can't cover this, this, and this. We either need to higher someone else, or I need to manage your expectations that these things just won't get covered. It's not that I'm not doing my job. You can see from this chart this is what I've been doing these past four months. There is just with not enough capacity to do it. But I can tell you that if the AD doesn't listen, it's the in-house counsel. How I know that, I'm a member of the National Association of College and University Attorneys, and I was at their conference on the heels of the CoSIDA conference. Their conference was in San Francisco. They're very dialed in to issues under the Fair Labor Standard Act. If your AD is not listening, talk to your university counsel and they can help in the hiring decisions. It's not that you're going above your AD. You're going in conjunction with your AD. Make sure you get them both. CLARK TEUSCHER: Does the threshold for exemptions change if someone is on a 10- or 11-month contract that has been floated as an option for some SIDs? TRACY WARREN: Yeah, it's a 40-hour work week, so it's still $47,476 for exempt employees. How that's paid is a different analysis. You can stretch that over a year, still making sure you're paying the minimum wage, or you can pay it in the ten months. We are seeing a lot of ten-month contracts for SID. CLARK TEUSCHER: Okay. Thank you very much. I think that is all the questions we have right now. We want to thank Tracy very, very much for her help and advice here today. We continue to appreciate Capital One's sponsorship of the CoSIDA Continuing Education series. The recording of today's webinar, and the ASAP Sports FastScript, will be available for on-demand use exclusively in CoSIDA's online community CoSIDA Connect later today. FastScripts Transcript by ASAP Sports   |
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