U.S. Department of Labor issues four wage-and-hour opinion letters on overtime and pay rules

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DOL wage-and-hour guidance

Highlights

The U.S. Department of Labor's Wage and Hour Division released four new opinion letters clarifying overtime and pay rules under the Fair Labor Standards Act.
One letter clarified overtime consequences for employees exempt under paragraph 13(a)(1) who perform secondary hourly jobs, directly impacting payroll practices.
Other letters addressed whether certain bonuses, meal-break movement on controlled premises, and pre-shift hospital worker activities—including rounding clock-in times—are considered compensable.

New guidance on compensation questions

As reported by the U.S. Department of Labor, the agency’s Wage and Hour Division is releasing the letters to improve clarity, consistency and transparency in applying federal wage-and-hour rules. The letters provide official written interpretations based on specific factual scenarios submitted by individuals, businesses or organizations, while also offering broader guidance for similar cases.

Wage and Hour Division Administrator Andrew Rogers says the letters explain how laws enforced by the division apply in workplace situations faced daily by employees and employers across the country. He says the latest guidance addresses longstanding Fair Labor Standards Act principles involving compensable time, exemptions and bonuses included in the regular rate of pay.

Implications for employers and workplaces

The four opinion letters focus on distinct compliance questions that can affect payroll practices and scheduling policies. One addresses whether an employee who is exempt under paragraph 13(a)(1) of the law can also perform additional work in a secondary hourly role, and what overtime consequences may follow.

A second examines whether a bonus based on comparing one employee’s straight-time and overtime earnings with those of all bonus-eligible employees qualifies as a percentage-of-total-earnings bonus under federal regulations. The remaining two letters address whether meal-break time spent moving through an employer’s controlled-access premises is compensable, and whether certain pre-shift activities by hospital workers count as paid work, including whether rounding clock-in times to scheduled shift starts is permitted.

Our earlier coverage of the Labor Department’s 2026 World Cup compliance push explained how employers in host cities can use federal tools to stay onside with wage, hour, and leave requirements as staffing and customer demand rise. We highlighted resources such as a dedicated compliance website, sector-specific toolkits, and the PAID program to help businesses proactively correct potential minimum wage, overtime, and FMLA issues, alongside in-person outreach from Wage and Hour specialists.

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