Wage & Hour Compliance: Timekeeping Policies & Procedures

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Wage & Hour
Compliance
TIMEKEEPING
POLICIES AND PROCEDURES
3/12/2016
1
Why the Training?
3/12/2016

The University must comply with
Federal and State Wage and Hour
laws for Non-Exempt employees
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Ensure consistent application of
time/record keeping practices and
payment of overtime for non-exempt
employees in accordance with
University policies (non-union) and
applicable CBAs (union)
2
New York State
Labor Law 195

All employers in
New York State
are required to
inform employees
hired on or after
October 26, 2009
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when they will be
paid
how frequently
they will be paid
the rate per pay
period.
Non-Exempt vs. Exempt
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Non-Exempt
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Exempt (from Overtime)
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3/12/2016
Paid on a hourly basis (no lump sum payments allowed)
Receive checks bi-weekly
Paid for overtime based on weekly hours worked (time
and a half for hours in excess of 35 per week under
applicable CBAs and University policy)
Complete timesheets
Must take and record lunch period
Must record all hours worked
Paid on a salaried basis
Not paid by hours worked/daily hours are not recorded
Not legally required to take lunch and breaks
All exempt employees need to be compensated on a salaried
basis at a rate of not less than $455 per week
4
Criteria for Non-Exempt Work
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Work is typically categorized as clerical in
nature: filing, filling out forms and preparing
routine reports, answering telephones, making
travel arrangements, copying, data entry and
processing
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Many clerical workers also exercise some
discretion and judgment in their jobs. However,
what distinguishes this from Exempt work is
that the exercise of judgment and discretion
must be about matters of considerable
importance to the operation of the
department or Columbia University as a
whole.
5
Criteria for Exempt Work
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Typically involves the exercise of discretion and judgment,
with the authority to make independent decisions on matters
which affect the department as a whole or a significant part
of it, or the University generally
Have the authority to formulate and/or interpret university
policies; has authority to waive or deviate from established
policies and procedures without prior approval
Have the authority to commit the University in matters which
have significant financial impact; has authority to negotiate
and bind the School/University on significant matters
Is involved in planning long- or short-term business
objectives
Have the authority to hire or fire other employees, or the
employee’s suggestion and recommendations as to the
hiring, firing, advancement, promotion or other change of
status must be given particular weight
6
Job Descriptions
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Job descriptions for all
employees, including hourly
casual and student workers,
must be evaluated for exempt or
non-exempt status
7
Hours of Work
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3/12/2016
Normal business hours set by
department
Generally, University business hours are
9 a.m. until 5 p.m. - seven hours per
day/35 hours per week (varies based on
department and area)
Supervisor & subordinates can agree on
variations providing business needs are
met (e.g., 8:30 – 4:30; 9:30 – 5:30)
Employee should arrive on time and
adhere to their schedule
Unpaid meal break is required if work
shift is 5 hours or longer
8
Overtime
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Must be approved in advance by
supervisor or management level
designee
OT must be paid at time and a half for
hours worked in excess of 35 hours in a
workweek
Comp time in lieu of OT is allowed for
2110 members. Must be used within 60
days from the time worked or paid out at
the rate of time and a half
If unapproved overtime is worked, it
must be paid and then dealt with as a
performance management issue
Compensation for All Hours Worked
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3/12/2016
Normal commute to and from work is
not compensable
Travel required by employer in order to
attend meetings or other work-related
activities is compensable
Working before or after-business hours,
from home, during lunch
Supervisors must be aware of &
anticipate the potential for overtime
costs for non-exempt employees
10
Time Records
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3/12/2016
Must document exact start and end
times
Timesheets should be completed on a
daily basis and submitted to the
supervisor on a weekly or bi-weekly
(depending on pay period)
Supervisor or pre-arranged
management level designee must sign
timesheet every pay period
Must reflect ALL hours worked.
Supervisor is responsible for managing
and approving all hours worked.
11
Time Sheet Instructions
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Estimating/rounding time
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Running department errands
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Do not round the time to
make it easier to add, i.e.
8:07 to 8:15
Record the exact start and
end work times
Not done during lunch hour
Lunch begins/ends when
errand is done/started
Meal Break
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Is generally 1 hour
(minimum of 30 minutes)
Record exact lunch times
Time Sheet Instructions
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Extended lunch period
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Time off with pay
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Record exact times
Use designated absence codes, I.e., “V”, “H”, etc.
Leaving Early / Arriving Late
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3/12/2016
Must be approved by supervisor in advance
Record exact times on the timesheet
Get prior supervisor approval
Dr. appointment
 Where appropriate use paid time off (consult HR or CBA if
applicable)
 Record exact times
Personal appointment
 Record exact times
 Make up time with approval
13
New Casual Timesheet
Facts & Tips for Supervisors
3/12/2016
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It is the responsibility of the Supervisor to
ensure that time sheets accurately reflect
the time worked
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The Supervisor’s signature on the
timesheet signifies that s/he has reviewed
and approved the time entered on the
timesheet
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If there is a problem with the timesheet, the
Supervisor should talk to the employee and
resolve the problem before signing the
timesheet
15
Questions?
3/12/2016
16
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