The Michigan Golf Course Owners Association recently held a seminar to discuss the Fair Labor Standards Act (FLSA). The FLSA was enacted in 1938, but, with proposed changes scheduled to take place later this year, the act has come under question recently. Much of the day's discussion impacted owners, however, many of the issues pertain to superintendents and include:
- I-9 Employment Eligibility Verification Forms - I-9 forms must be filled out and filed for every employee who works at the golf course, including all of those on the grounds crew. These forms should remain on file for a minimum of three years after the conclusion of employment for each employee.
- Non-Exempt vs. Exempt Employees - Non-exempt employees may be paid on an hourly basis, must earn at least minimum wage, and must be paid overtime for all hours over 40 worked in one work week. Exempt employees are generally salaried employees (many superintendents and assistants fall in this category), must be paid at least $455/week (proposed change would see this salary number jump to $921/week) and meet the job duties of one of the white collar exemptions.
- Payroll Records - Along with I-9 forms, payroll records must be retained for a minimum of three years following the end of the year to which they relate.
- Posting Requirements - All employers are required to post the FLSA minimum wage provision in an area where their employees congregate, such as the break room or lunch room. FLSA posting's vary by statues so please check the posters page to find out which postings you need to display in your facility. Postings typically change year-to-year, so instead of purchasing the large laminate posters, the forms can be printed on 8" x 11" sheets of paper and re-hung when changes occur.
- Preventative Measures:
- Regularly review time records for accuracy. Make sure any changes made to hours worked have both the supervisor's and employee in question's approval.
- Develop accurate job descriptions. Job descriptions are important. Be sure the description is written based on the job itself, and the not the person currently performing the job. It is also important, under the 'Duties and Responsibilities' area of the description to add: 'Additional duties assigned by the supervisor'.
This only covers a brief snapshot of the entire FLSA, as the act covers additional information. I would encourage you to visit the DOL's FLSA website for more information on the FLSA, and to review the proposed changes which may directly impact your facility and employees.