November 2024 FLSA Minimum Salary Update

The U.S. Department of Labor (DOL) and the New York State Department of Labor (NYSDOL) have issued revisions to the Fair Labor Standards Act (FLSA) with respect to the minimum salary threshold for overtime eligibility for employees. These changes will have some impact on Columbia University, as they will on most employers in the United States.

Key provisions of the law

• Full-time employees who earn less than the applicable minimum weekly rate are considered non-exempt and must earn overtime pay if they work more than 40 hours in a week.
• There is no proration for part-time employees. An employee must earn the applicable minimum, regardless of the number of hours worked, or be converted to a non-exempt position that is overtime eligible.

Officers of Research and the Libraries
Officers of Research and the Libraries are subject to the U.S. DOL minimums. The salary threshold increased effective July 1, 2024, to $844 per week ($43,888 per year); the second increase goes into effect on January 1, 2025, to $1,128 per week ($58,656 per year)

For Officers of Administration
Officers of Administration are subject to the New York State minimums. The salary threshold increased effective January 1, 2024, to $1,200 per week ($62,400 per year); the second increase goes into effect on January 1, 2025, to $1,237.50 per week ($64,350 per year); A third increase will go into effect on January 1, 2026 to $1275 per week ($66,300 per year).

What does this mean for Columbia University?
Effective January 1, 2025, the changes apply to Officers of Research and Officers of the Libraries who earn less than $1,128 per week ($58,656 per year) and Officers of Administration who earn less than $1,237.50 per week ($64,350 per year).

Full-time Officers of Research and Libraries
As the current full-time minimum salaries set by the Office of the Provost are above the new federal threshold, no changes will be needed.

Part-time Officers of Research and Libraries
Part-time Officers who earn less than $1,128 per week must either be brought up to the new minimum or be converted to an Hourly Officer

Full-time Officers of Administration
The salary minimums will be adjusted as of 1/1/25, and any full-time Officer of Administration currently below the new threshold must be brought up to the new minimum salary

Part-time Officers of Administration
Part-time Officers who earn less than $1237.50 per week must be brought up to the NYSDOL minimum or will be converted to an Hourly Officer

What does this mean for full-time Officers of Research and Libraries?
Full-time Officers of Research and full-time Officers of the Libraries are already paid at the higher, University-established salary minimums, so this change will not have an impact on them.

What does this mean for current part-time officers of Research?
Effective January 1, 2025, all part-time Officers of Research and of the Libraries who earn less than $1,128 per week must either be brought up to the new minimum salary of $1,128 per week (there is no proration) or will be converted to an Hourly Officer. If you have already reappointed a part-time Officer of Research or of the Libraries at the new $1,128/week rate beyond December 31, 2024, you cannot reduce the salary until their next appointment renewal. Individuals moved into the new Hourly Officer category will be required to submit timesheets on a bi-weekly basis, in accordance with their local department practice for timesheets.

Hourly Officers who are moved to the bi-weekly pay cycle starting January 1, 2025, will be paid every other Friday beginning on Friday, January 17, 2025.

All requirements related to length of appointment remain in place. Part-time Officers of Research and of the Libraries must not work more than 18 hours per week during the term of their appointments. If you have questions, please reach out to the Office of the Provost or CUIMC Office of Faculty Affairs, as applicable.

What does this mean for new part-time Officers of Research?
Effective January 1, 2025, newly hired/rehired/reappointed Officers of Research and Officers of the Libraries must either be paid at a rate no less than $1,128/week or be hired as an Hourly Officer. Schools and departments should follow their existing process on how to request new position numbers for Hourly Officers of Research or of the Libraries.

What does this mean for full-time Officers of Administration?
Full-time Officers of Administration who are paid below the NYSDOL minimum must be brought up to the new salary minimum. The University minimums will be adjusted accordingly.

What does this mean for current part-time Officers of Administration?
Effective January 1, 2025, all part-time Officers of Administration who earn less than $1,237.50 per week will be converted to an Hourly Officer. Individuals moved into the new Hourly Officer category will be required to submit timesheets on a bi-weekly basis, in accordance with their local department practice for timesheets.

Hourly Officers will be moved to the bi-weekly pay cycle and will be paid every other Friday beginning on Friday, January 17, 2025.

What does this mean for new part-time Officers of Administration?
Effective January 1, 2025, newly hired/rehired/reappointed Officers of Administration must either be paid at a rate no less than $1,237.50/week or be hired as an Hourly Officer.

Next Steps

• The Provost’s Office, CUHR Business Partners, CUIMC Faculty Affairs, and CUIMC Payroll will work directly with those departments who have officers that are impacted by the DOL and NYSDOL FLSA changes.
  • Detailed lists of the employees affected by this change, and the process to update their employment classification will be provided to the departmental administrators for those schools/departments in the next couple of weeks. Schools/departments with no employees impacted by the FLSA changes will not receive any additional information at this time.
  • Schools/departments must set the minimum hourly rate to be equivalent of a full-time employee in the same role. Example: if you hire an hourly officer as a Staff Associate I, their minimum hourly rate as per 2024-25 Provost’s minimum salary guidelines is $62,400/(35*52) which equals to $34.29 per hour.
  • Deadlines for submission of changes will be provided along with the employee lists.
• Communication materials including template letters will be provided for departmental administrators and/or managers to use to notify the individual employees.
• Communication to impacted employees will be delivered by a combination of departmental administrators, department HR and/or managers.
• A NYS 195 form will need to be completed and signed by each employee who is either receiving an increase or who is being converted to an Hourly Officer. The signed forms must be submitted with the transaction.

Questions
Please contact any of the following individuals with specific questions:

For information about appointments:

• Morningside campus: please contact Carmen DeLeon, Associate Provost for Academic Appointments, [email protected]  or Zeid Sitnica, Associate Provost for Academic Appointments, [email protected]
• Officers of Administration: please contact Peter Panycia, Associate Director for Compensation, [email protected]
• CUIMC: please contact Lenny Ruiz, Senior Executive Director, CUIMC Payroll Service Center, [email protected], or Dionida Ryce, Assistant Vice President for Academic Appointments and Professionalism, [email protected]