HomeMy WebLinkAboutIR 7107 •i INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 7107
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To the Mayor and Members of the City Council
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;TexP� Subject: UPDATE ON THE FAIR LABOR STANDARDS ACT AMENDMENTS OF 1985
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Summary. President Reagan recently signed into law amendments in the Fair Labor
Standards Act that will change provisions affecting employees of State and local
governments. After the Supreme Court decision in Garcia v. the San Antonio
Metropolitan Transit Authority on February 19, 1985, Fort Worth and other
municipalities and their employee representatives identified a number of areas
which would adversely affect local government operations . Although the City of
Fort Worth proceeded to come into compliance with the wage and hour law, the
City Council and staff supported efforts of public interest groups for
administrative and legislative relief. Pending final action by the Congress, the
City withheld paying retroactive payment of overtime premium pay required by the
act , but implemented appropriate procedures to comply with the Act assuming
enforcement of the Act by the U.S. Department of Labor prospective from
April 15, 1985.
The legislation signed by the President, responds to some of the concerns of
local governments. Generally, the legislation provides for compensatory time in
lieu of immediate overtime pay in cash, clarifies the law as it relates to joint
employment by police officers and fire fighters, sets the effective date as
April 15, 1986, and relieves local governments from having to pay retroactive
overtime pay. The amendments also clarified the status of volunteers and
prohibited discrimination against employees who asserted overtime coverage under
FLSA after February 19, 1985. A summary of the amendments is included with this
report as Attachment A.
CFW IMPLEMENTATION PROCEDURES
City staff has prepared for implementation of the Fair Labor Standards Act for
City employees. On July 2, 1985, the Council approved a set of Personnel Rules
and Regulations pertaining to the Fair Labor Standards Act. The majority of
these regulations will require only a change in effective date since they
address definitions and procedures under FLSA.
Seven of the regulations required revision to conform to changes in the FLSA act
and its new effective date of April 15, 1986. Following is a list of the revised
regulations and a summary of the revisions.
C.4 OVERTIME PAY/COMPENSATORY TIME FOR MUNICIPAL EMPLOYEES
Current overtime and compensatory time policies allow either overtime pay or
compensatory time for hours worked in excess of 40 hours by non-exempt
employees . Accrual of compensatory time is unlimited. The revised FLSA
regulations permit accrual of 240 hours of compensatory time nor regular
employe-.s and 480 hours for employees in public safety, emergency response or
seasonal activities.
City staff proposes that a cap of 120 hours of compensatory time for all
employees be approved. Hours worked above that limit would have to be paid at
the time-and-one-half rate of pay for non-exempt employees. Exempt employees
ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS
UPDATE ON THE FAIR LABOR STANDARDS ACT AMENDMENTS OF 1985
PAGE TWO
with 120 hours of accrued compensatory time would not have any additional hours
added for overtime work. City employees with accrued compensatory time in excess
of the 120 hour limit would have those hours transferred to Major Medical/Sick
Leave on a one time basis. Employees could not accrue further compensatory time
until they had used some of the accrued time.
C.23 WAGE-HOUR POLICY: KEY "TIME: DEFINITIONS
Minor word change that does not impact the regulation.
C.31 WAGE-HOUR POLICY: ADJUSTING WORK SCHEDULE FOR BUDGET REASONS
Policy revised to conform to the latest amendments to FLSA which allow use of
compensatory time by state and local governments.
C.32 WAGE-HOUR: POLICY: DUAL EMPLOYMENT
Previous policy defined dual employment under terms of the prior FLSA act.
The revised policy changes the definition to conform to the latest amendments to
FLSA which specifically addressed the needs of state and local government.
C. 34 WAGE-HOUR POLICY: DECLARATION OF POLICE AND FIRE CIVIL SERVICE WORK PERIODS
The revised regulation changes the effective date of the workperiods from
July 6, 1985 to April 12, 1986.
C.35 WAGE-HOUR POLICY: DECLARATION OF CRASH/FIRE RESCUE PERSONNEL WORK PERIODS
The revised regulation changes the effective date of the workperiods from
July 6, 1985 to April 12, 1986.
D. 17 TERMINATION PROCESSING
Previous termination processing did not permit payment for compensatory time to
non-exempt employees who terminated employment.
Amendments to the FLSA act require the non-exempt employees be paid at
termination for compensatory time earned after April 15 , 1986. The rate of
payment for the accrued compensatory time will be at a regular rate of not less
than the higher of the employee 's final regular rate or the average regular rate
during the last three years of employment.
IMPLEMENTATION DATE
The Fair Labor Standards Act become effective for state and local governments on
April 15, 1986. It is proposed that the Council approve the revised regulations
during the City Council meeting on April 8, 1986, in order to meet the federal
enforcement date.
Respectfully submitted,
i ,"bouglas Harman
City Manager -��
Summary of FLSA Amendments
Compensatory Time. State and local governments are permitted to give their
employees compensatory time off in lieu of immediate overtime pay in cash, at a
rate of not less than one and one-half hours for each hour of overtime worked,
but only pursuant to a collective bargaining agreement, or an agreement or
understanding arrived at between the employee and employee before performance of
the work. The regular practice of granting compensatory time off in lieu of
overtime compensation in effect on April 15, 1986 , shall be considered an
agreement or understanding.
The maximum compensatory time which may be accrued by any affected employee
shall be 480 hours for those engaged in a public safety, emergency response, or
seasonal activity, and 240 hours for all other employees after April 15, 1986.
An employee who has accrued the maximum number of compensatory hours shall be
paid overtime compensation in cash for any additional overtime hours of work.
An employee shall be permitted to use accrued compensatory time within a
reasonable period after it is requested if to do so would not unduly disrupt the
operations of the employing public agency.
Payment for accrued compensatory time upon termination of employment shall be
calculated at the final regular rate received by the employee or the average
regular rate during the last three years of employment, whichever is the higher.
"Compensatory time" and "compensatory time off" are defined as hours when an
employee is not working and which are paid for at the employee's regular rate of
pay. These hours are not counted as hours worked in the week in which they are
paid.
Multiple Job Situations. Employees of a State or local government agency who are
employed in fire protection, law enforcement, or related activities may at their
own option agree to a special detail to work for a separate or independent
employer in such activities. The hours worked for the separate and independent
employer (public or private) shall be excluded from hours worked for overtime
pay purposes by the original employing agency. This provision shall apply even
if the principal employer requires that only certain individuals may engage in
the employment by the separate and independent employer and facilities or
affects the conditions of employment.
Employees of a State or local government may at their own option undertake
employment for the same employer on an occasional or sporadic basis in a
part-time job in a different capacity than their regular employment. The hours
of work in the different job shall not be counted as hours worked for overtime
pay purposes on the regular job.
Employees of State and local government agencies at their own option but with
the approval of their employer may substitute during scheduled hours for other
employees employed in the same capacity. In the case of such substitution, the
hours involved are credited to the scheduled employee and not to the substitute
employee. The employee need not maintain a record that the substitution has
taken place.
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Summary of FLSA Amendments
Volunteers . Individuals who volunteer their services to State or local
governments and receive no compensation, are excluded from the definition of
employee and are thus excluded from coverage. They may be paid expenses ,
reasonable benefits, nominal fees , or a combination of these. However , an
employee of a State or local government may not volunteer to his own agency
services of the same type the employee is employed to perform.
An employee of a State or local government agency may volunteer services to any
other State or local government agency, including agencies with which the
employing agency has a mutual aid agreement.
Discrimination. A State or local government agency that discriminates against an
employee because the employee asserted overtime coverage under FLSA after
February 19 , 1985 , shall be held to have violated the anti-discrimination
provisions of FLSA.
Liability and Deferred Payment. No State or local government agency shall be
liable under section 16 of FLSA for a violation of overtime pay or related
recordkeeping provisions which occurred before April 15, 1986, if the affected
employee would not have been covered by FLSA under the Secretary of Labor ' s
special enforcement policy on January 1 , 1985, as published in sections 775.2
and 775.4 of 29 CFR Part 775.
A State or local government may defer to August 1, 1986, the payment of monetary
overtime pay due employees for hours worked after April 14, 1986.
Effective Date. The effective date of the Fair Labor Standards Amendments of
1985 is April 15, 1986.