Your first steps: Gauge the impact of new OT threshold.

• Position: Nuts & Bolts

Although the DOL's proposal to raise the overtime salary threshold to $35,308 per year probably won't take effect until at least Jan. 1, 2020, employers should start planning now how they will respond.

There are two ways to minimize the impact:

Give raises to affected employees so their salaries are higher than the proposed threshold. Those employees could then work more than 40 hours per week without triggering an overtime pay obligation. For employees whose annual earnings are already close to $35,308, this makes sense.

Crack down on overtime so that exempt, overtime-eligible employees never work more than 40 hours per week. This may be easier said than done if unwritten rules set expectations that staff will perform some work after hours and on weekends. Remember, employers must always pay time-and-a-half for overtime work, even if the overtime was unauthorized.

Final thought: For many employers...