On April 23, 2024, the U.S. Department of Labor
("DOL") released a new final rule that significantly increases the
minimum salary threshold to qualify for the executive,
administrative, professional, and highly compensated employee
exemptions under the Fair Labor Standards Act ("FLSA").
Initial increased salary thresholds are scheduled to take effect on
July 1, 2024, followed by additional increases just 6 months later
on January 1, 2025, and then followed by automatic increases in
subsequent years. Employers must act quickly to prepare for the
implementation of this new rule, which will impact approximately 4
million workers nationwide. More specifically, absent any
successful legal challenges, employers will need to either (A)
raise the salaries of many exempt employees, or (B) reclassify
certain exempt employees to non-exempt and overtime eligible, while
also accounting for the impact these compensation changes may have
on the employer's overall compensation schemes.