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Rebecca Farley

Director, Policy & Advocacy, National Council for Behavioral Health

National Council Issues Template Comments on Proposed Overtime Rule

August 27, 2015 | Take Action | Workforce | Comments
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New proposed rules from the Department of Labor would double the current salary threshold for employees exempt from overtime pay. As a result, employers would be required to pay overtime for employees making up to $50,440 per year. The proposed rule would link this salary to inflation, meaning that the overtime exemption threshold would rise from year to year. Public comments on the proposal are being accepted through September 4, 2015.

The National Council is concerned about the impact of this proposed rule on member organizations operating with tight margins under reimbursement rates set by third-party payers that limit employers’ ability to adapt to these changes. Therefore, today we are issuing a template comment form that can be used as the basis for members’ comments to the Department of Labor.

The template comment letter recognizes the importance of raising wages for lower-earning workers, yet notes that community behavioral health providers have limited ability to raise new revenue in response to increased costs of doing business. Provider organizations would be squeezed more tightly with every year that goes by; many could be forced to close programs and lay off staff.

To submit your comment:

  1. Download the template comment letter.
  2. Personalize it where indicated with information about how your organization could be affected.
  3. Submit your comment online at regulations.gov (click “Comment Now” in the right-hand sidebar and fill in all required information).

Click here for our coverage on the impact of the proposed rule.