FLSA and Postdoctoral Salary Threshold

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FLSA and Postdoctoral Salary Threshold

To: UA Principal Investigators and Campus Research Community

From:

Andrew C. Comrie, Senior Vice President for Academic Affairs and Provost

Kimberly A. Espy, Senior Vice President for Research

Subject: FLSA and Postdoctoral Salary Threshold

Date: November 23, 2016

The University of Arizona is committed to providing our Postdoctoral Research Associates an outstanding mentored training experience that is compensated equitably. Postdoctoral Research Associates provide significant contributions in our research programs and are invaluable to our scholarly mission. Implementation of the requirements under the Fair Labor Standards Act (FLSA) is underway and it provides us both the opportunity and responsibility to address compensation for this group. There are two key parts to FLSA implementation at the UA, with further important details following below:

  1. Diligence in reporting hours and compensatory time, effective immediately;
  2. Raising salaries to the new FLSA threshold by next summer, no later than July 1, 2017.

During the FLSA comment period, many universities, academic faculty, and scientific professional organizations, including National Institutes of Health (NIH), provided feedback to the Department of Labor on the importance of supporting the significant contributions of postdoctoral researchers and recommended an increase for postdoctoral compensation. Most universities are raising salaries for Postdoctoral Research Associates in order to remain competitive with other institutions seeking those future scientific leaders.

The FLSA changes will take effect at the University of Arizona (UA) on Nov. 21. Approximately 2,200 UA employees, including 200 Postdoctoral Research Associates who are under the new and updated $913 weekly pay threshold, will become non-exempt employees at this time. Under FLSA requirements, these employees must be offered compensatory time or overtime pay for hours worked beyond 40 each week. They will also be required to report all time worked in a pay period in order to receive pay in a timely manner.

In August 2016, the National Science Foundation (NSF) and the NIH announced that both agencies would raise stipend levels to the updated FLSA threshold for all new or renewed grants. This announcement necessitated a consistent approach to ensure equity for all Postdoctoral Research Associates at the UA.

The UA will require that all Postdoctoral Research Associates be raised to the new FLSA threshold no later than July 1, 2017. We recognize that increased salaries will impact other financial and staffing operations, and we will work closely with Principal Investigators and supervisors to aid in a smooth transition on the following:

  • Effective Nov. 21, Postdoctoral Research Associates under the updated FLSA threshold (annualized salary of $47,659) must be diligent about reporting hours worked in UAccess; principal investigators, faculty, and other time approvers must be attentive about approving time appropriately in UAccess.
  • Compensable time for Postdoctoral Research Associates includes all time they are required to be at work or performing any job-related duties in or away from the office or laboratory. This FLSA obligation marks a significant cultural and operational change to how these employees have been managed, but adherence to the new regulations is essential. Postdoctoral Research Associates must not be asked to report time that is different from what was actually worked, and they cannot volunteer their effort or time.
  • Between now and July 1, 2017, the salaries of Postdoctoral Research Associates should be raised to the new FLSA threshold as funding becomes available.
  • Effective immediately, all sponsored proposals and revised/amended budgets must reflect the new FLSA salary threshold for Postdoctoral Research Associates.
  • One-time institutional funds will be available to units effective July 1,2017, to address the required increases for personnel that can demonstrate hardship on current funding sources to raise Postdoctoral Research Associates to the new FLSA threshold.

Research, Discovery, and Innovation, in partnership with the Division of Human Resources and the Office of the Provost, will work with the research community to develop guidance on Postdoctoral Research Associate compensation and to evaluate the impact of the new FLSA requirement.

Principal Investigators affected by these changes should work with their college and department business offices on plans to implement the new FLSA threshold for all Postdoctoral Research Associates by no later than July 1, 2017. Additional information will be distributed by January 31, 2017, on the process to apply for one-time institutional funds for the demonstrated hardship cases.

Questions may also be directed to your designated Human Resources Consultant. To identify your Human Resources Consultant and his/her contact information, please visit http://hr.arizona.edu/supervisors/consulting-services.

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