Robert (Rob) J. Reid, J.D.
Margaret (Meg) Paul, SPHR
100 East Eighth Street
Cincinnati, Ohio 45202
The Department of Human Resources offers the highest quality of service by developing with its partners a work environment that is built on trust and respect for each individual.
The Department of Human Resources provides development, oversight, support and direct services in the area of Human Resources for archdiocesan offices, parishes, schools and other archdiocesan institutions while insuring compliance with its mission, the values of the Catholic Church, and relevant governmental regulations and professional standards.
SPOTLIGHT OF THE MONTH
The Department of Human Resources will be holding Informational Meetings on the Department of Labor (DOL) Final Overtime Rule, which is set to take effect on January 1, 2020. These meetings are open to pastors, business managers and others who are responsible for wage-hour law compliance and the implementation of the Final Overtime Rule. Specific information regarding these sessions is as follows:
St. John the Evangelist Church Wednesday, December 4 10-11:00 a.m.
9080 Cincinnati-Dayton Rd. Education/Activity Center
West Chester, OH 45069
St. Christopher Church Wednesday, December 11 10-11:00 a.m.
435 E. National Rd. Emmaus Center
Vandalia, OH 45377
DEPARTMENT OF LABOR FINAL OVERTIME RULE
On September 24, 2019, the U.S. Department of Labor (DOL) issued the long-anticipated final overtime rule. Here are the highlights of the final rule:
- The annual salary threshold for exempt positions will jump from $23,660 to $35,568 (or from $455 to $684 per week). With the exception of teachers and the clergy, employees who earn less than the threshold must be paid for over 40 hours worked in a workweek at a rate not less than time and one-half their regular hourly pay rate—even if they’re currently classified as a manager or professional and regardless of whether they are full or part-time.
- There will be no change in the duties test used to determine whether employees earning more than the salary threshold must be classified as non-exempt from overtime, including the exemptions for executive, administrative and professional positions, among others.
- The new rule takes effect on January 1, 2020.
Please use the above effective date as a timeline for implementing any needed changes to your exempt/non-exempt classifications.
If you have not done so already, we recommend that you analyze the number of hours worked per week/month/year for each employee who is currently classified as exempt and whose salary is below $35,568 per year. This analysis is necessary so that an accurate hourly rate can be established when the employee is converted to non-exempt status. In other words, the goal is to set an hourly rate that will, as closely as possible, result in the employee being paid the same yearly salary as they are currently paid. Please pay close attention to any overtime hours (i.e., hours over 40 per week) that the employee works, as these hours will need to be factored into the setting of the hourly rate. By way of example, an employee who regularly works five hours of overtime per week will require the setting of a lower hourly rate to offset the overtime premium of “time and a half” for each hour of overtime.
If you need further assistance, please contact Rob Reid at (513) 263-6611, firstname.lastname@example.org or Meg Paul at (513) 263-3341, email@example.com in the Department of Human Resources.
Just a reminder that the Conflict of Interest Disclosure Statements are due by December 1, 2019. Each year responsible individuals who hold decision making or policy setting positions or who purchase equipment, supplies or other goods, must sign the form. All Disclosure Statements must be kept in a confidential file (at your location) under lock and key.
If you have any questions regarding this reminder, please contact Rob Reid at 513.263.6611.
Please click for the Conflict of Interest Disclosure Statement.
This document is intended to provide school administrators and pastors information about employment of students during and after school and through the summer months. Students under the age of 18 are considered minors and may not work at anything that is hazardous or injurious to their health and well-being including: activities involving flammable substances, gases, vapors or fumes; activities involving driving a school bus, motor van or any motor-propelled vehicle. Additionally, the Child Protection Decree must be followed regarding supervision of student employees. Click for full document.
If you have any questions concerning this matter, please contact Rob Reid at (513) 263-6611, firstname.lastname@example.org or Meg Paul at (513) 263-3341, email@example.com in the Department of Human Resources.
For all non-teaching employees (called “at-will” employees), it is very important to put their employment status and employment specifics in writing (i.e. job title, salary/hourly rate, benefits eligibility, full or part-time, exempt/non-exempt, etc.). For new employees, the offer letter would serve this purpose. For current employees, we recommend a Memo of Understanding that is signed by both you and the employee. For both of these documents, in addition to basic employment information and confirmation of at-will employment status, of particular importance is the necessity to put in writing that both new and continued employment are conditioned upon a clear background check, that the initial VIRTUS/Child Protection Training is successfully completed, and finally, the employee remain current with monthly VIRTUS Bulletins.
There is a sample offer letter on the Human Resources webpage to which you can refer.
NON-EXEMPT EMPLOYEES and OVERNIGHT WORK
With continued attention from the Department of Labor (DOL) on the correct classification of employees as exempt or non-exempt, we want to clarify how wages are paid for a non-exempt, hourly employee when going on an overnight retreat (or reasonable facsimile); for example, a CRE or Youth Minister accompanying a group of high school students on an overnight Kairos retreat.
When a non-exempt employee is required to be “on duty” for 24 hours or more, the employer may exclude a scheduled “sleeping period” of not more than eight hours from hours worked. This means 16 of the 24 hours would be paid.
Additionally, the DOL requires that the employee be provided with a notice prior to the overnight event that outlines how the upcoming hours will be paid. This should be signed by both employer and employee then filed in their personnel folder.
For those times when a non-exempt employee is required to work more than their regular schedule, but less than 24 hours, no sleeping period is allowed; all of these hours must be paid even if the employee is allowed time to sleep. For example, a CRE or Youth Minister arrives at the retreat at dinner time, participates in evening activities, stays overnight, then leaves the next morning.