USDOL Self-Report PAID Program: Benefits TBD

Last week the U.S. Department of Labor (USDOL) announced its Payroll Audit Independent Determination (PAID) pilot program to mixed reactions. The PAID program is meant to provide a framework for employers to proactively resolve potential federal Fair Labor Standards Act (FLSA) claims. In a nutshell, an employer will be able to self-report potential violations to USDOL and attempt to resolve the issues efficiently and under the agency's "supervision," as outlined on its website.

While one can speculate as to what the full terms of the forthcoming pilot program will be, and most likely employers will find them preferable to litigation, thus far the benefits and risks are not particularly distinguishable from an investigation.