Extract to table

The timing of this reclassification — coinciding almost precisely with the outer boundary of the three-year willful-violation lookback period — raises questions about the basis for the reclassification decision that must be explored in further factual development

602): The employee must be compensated on a salary or fee basis at not less than the applicable minimum threshold amount per week

200(a)(1)): The employee's salary must meet or exceed the minimum salary threshold established by DOL regulation

200(a)(2) and (a)(3)): The employee's "primary duty" must be (a) the performance of office or non-manual work directly related to the management or general business operations of the employer or the employer's customers, and (b) must include the exercise of discretion and independent judgment with respect to matters of significance

basis" — that is, the employee must receive a fixed, predetermined salary that is not subject to reduction because of variations in the quality or quantity of the employee's work

Even under the lower $684/week threshold, VHG must confirm that all lead/senior exempt-classified employees are in fact compensated at or above this level on a true salary basis