Comstock's magazine 0919 - September 2019 | Page 25
The Fair Labor Standards Act has strict rules
regarding paying nonexempt employees, and California
is even stricter. One of the key components is that
employees must be paid for every hour they work.
One of the key components is that em-
ployees must be paid for every hour they
work. By not keeping accurate hours, your
boss has opened the company up to pos-
sible disastrous results if someone com-
plains or if the U.S. Department of Labor
does an audit.
I’m sure he’ll argue he’s adding to their
paychecks, not taking away from them, so
there’s not a problem. And it’s probably
true that none of the employees are going
to complain about extra money in their
paychecks.
But that’s not the only problem. Let’s
talk about fraud. Let’s talk about theft.
Because that is what is going on. Employ-
ment attorney Jon Hyman says he prob-
ably wouldn’t advise a company to press
charges in this situation, but he would ad-
vise that the manager be fired.
He’s put you in a terrible situation.
You’ve got to tell employees their pay-
checks are going to be cut, and you need
to report what has been going on to hu-
man resources. If you don’t report it, you
are complicit in the fraud. And as much
as you want to forget this, at least one em-
ployee will complain about how you cut
pay, so it’s no longer going to be a secret.
1 Report the fraud to HR or to pay-
roll or to your boss’s boss. Any one of
those is fine.
2 Meet with HR to discuss salaries
for your employees. Make sure they are
currently receiving market rate salaries;
if they aren’t, create a plan to increase
their pay.
3 Sit down and meet with the em-
ployees. Normally, tough conversations
should be held one-on-one, but because
this is the same conversation with ev-
eryone, you can do it as a group. Explain
that you have to bring paychecks into le-
gal compliance. That means:
• People clock in when they arrive at work
and clock out when they leave.
• If they work additional hours at home,
they must clock in at home and clock
out when finished.
• Lunch breaks will be accurately record-
ed. Keep in mind, California has strict
break laws that you need to comply
with, making working through lunch
almost always illegal.
• Employees will be paid for overtime (in
California, that’s more than eight hours
in one day and more than 40 hours in
one week).
• If you and HR agree that salaries should
be adjusted, tell them you’re working
on it.
Make sure you express how much you
appreciate their work and how excited
you are to be working with them. They will
probably not be happy, although you may
find that some are relieved that the pro-
cess will be legal now. You will need to be
an extra awesome manager to help during
this transition, but you’re likely to experi-
ence some turnover due to this as well.
The biggest lesson here is how much
of a mess things can become when some-
one ignores the law and best practices in
an attempt to be nice. n
Suzanne Lucas spent 10 years in corporate
human resources, where she hired, fired,
managed the numbers and double-
checked with the lawyers. On Twitter
@RealEvilHRLady. Send questions to
[email protected].
Have you ever had to work during what
should be your lunch break?
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