The recent changes to FLSA overtime regulations have significant implications for those of us in the Housing and Residence Life profession. The rules go into effect on December 1st, 2016, and you can bet there will be no shortage of discussion on this topic at every local, regional, and national association meeting.
The topic of labor costs has received the lion’s share of professional attention from housing professionals and for good reason: student housing is a 24/7/365 service that requires professional skill and experience to manage risk and promote student learning. As of December 1, 2016, many of the previously overtime-exempt housing positions providing these campus services will fail the FLSA salary test, requiring the employer to provide overtime compensation. This infographic illustrates projected increase in labor costs in these positions.
Under this labor regulation, most schools will choose to track working hours and prioritize job expectations to limit overtime expense. This prioritization will illuminate the values of the unit and its supervisors to prospective and current entry-level staff. Unit supervisors who curate a transparent professional progression in both unit specific training and professional development will position their jobs as attractive opportunity in a workplace landscape that will be uncertain and rapidly changing over the next decade.
Consider that fiscal year 2017 (FY17) housing rates have already been established for many housing programs, limiting revenue-generation options. Additionally, staffing for FY17 is also mostly complete at many schools; barring layoffs, staff reduction is also unlikely. This leaves cost containment the most directly accessible option. An RD making $35,717 ($17.17/hr) per year would need to work about 457 hours of overtime ($25.75/hr) in a year before salaried compensation reaches the FLSA standard of $47,476 per year overtime-exempt threshold. That’s about a 48 hour per week average for the entire year. Departments with 48 hour weekly averages should consider they may already have a “priority problem” among staff, which supervisors will be required to address if labor costs are to be contained.
Supervisors will need to actively manage, and limit, the working hours of entry-level professionals to contain labor expense within the salary band. Each assigned weekly hour of work below forty hours takes on greater relative value under these new regulations. In systems with on-call responsibilities, budgeting hours to accommodate the estimated time on-call will further reduce the working hours available. For example, a RD working a 7 day on-call shift on the “waiting to engage” model, averaging about 2 hours of calls outside the 8 hour workday, is going to rack up 14 hours of overtime ($361) each 7 day shift.
Each unit will need to analyze and prioritize the work it requires of RDs. For many units, a logical response is to schedule each RD below forty hours per pay period to accommodate evening work with students and on-call response and reducing the frequency of overtime. As the scheduled week is reduced, so are the opportunities for collaboration with other administrative personnel, collateral assignments, and professional development. More specifically, each hour spent on these activities increases the likelihood that the unit will need to compensate the RD for priority responsibilities at the overtime rate.
The increased relative value of each workday hour requires thoughtful planning and documenting of each RDs professional development. This is necessary for both for unit policy compliance (e.g., Title IX, purchasing, etc…) and for the cultivation of skills necessary to prepare entry-level staff for next mid-level positions within the unit and the larger housing profession.
With limited hours available, the supervisor must critique current self-guided professional development plans to ensure the restructured time still encourages professional learning. Curating a progression through unit and campus responsibilities over a two-to-three year period, will be essential to ensuring entry-level professionals develop mid-levels skills while remaining available to complete essential tasks within the forty hours work week. Identifying necessary skills and opportunities for staff to demonstrate competency in those skills outside a formal training session, will be an essential supervisory function.