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Free Decision File • FLSA Exemptions

Exempt vs. Nonexempt Classification File

Build a defensible exemption file per position: salary basis, salary level, duties test, and a review date — before the DOL builds theirs.

Ask an employer why a position is exempt and the answer is usually a title, a salary, or a shrug — 'they're a manager,' 'they're salaried,' 'they've always been exempt.' None of those is a legal answer. Exemption requires salary basis, salary level, and a duties test measured against what the person actually does — and misclassification means back overtime for every week, every incumbent, across the look-back period.

This file documents the answer per position: the salary basis checks (including the partial-day docking trap), the current threshold math, a duties table for all five major exemptions with an evidence section that demands real time percentages and named decisions, consistency checks across departments, and a decision record with a standing review date.

Who should use this decision file

  • Employers with salaried 'managers,' 'coordinators,' and 'administrators' never formally tested
  • HR teams responding to DOL threshold changes
  • Owners about to promote someone into a salaried role
  • Anyone whose exempt employees have started tracking their hours

What it helps prevent

  • Misclassification liability: back overtime for every affected week, times every incumbent
  • 'Salaried means exempt' folklore driving classification
  • Manager titles with no management duties behind them
  • Improper salary deductions quietly destroying the salary basis
  • Reclassification scrambles when thresholds move

What’s inside

  • Part 1 — Position Snapshot
  • Part 2 — Salary Basis Test
  • Part 3 — Salary Level Test
  • Part 4 — Duties Test (the one that fails)
  • Part 4a — Duties Evidence
  • Part 5 — Comparison and Consistency
  • Part 6 — Decision and Review

Before you process payroll, terminate, classify, deduct, or respond to a claim, get the decision reviewed.

Faulkner HR Solutions helps Texas employers, nonprofits, municipalities, and growing businesses fix the people systems behind recurring workplace problems. If this resource raised a risk flag, do not guess your way through the next step.

Frequently asked questions

If someone is paid a salary, aren't they exempt?
No — salary is one of three tests, and the easiest one. The duties test is where classifications fail: an exempt title with nonexempt work is just unpaid overtime with better business cards. The file's Part 4 tests duties against what the incumbent actually does all week.
What's the most common misclassification?
The working supervisor: a 'manager' who spends most of the week doing crew work with incidental oversight. Executive exemption requires management as the primary duty plus genuine authority over personnel decisions — and the evidence section asks for exactly that documentation.
What breaks the salary basis?
Improper deductions — most often docking for partial-day absences or slow weeks. A pattern of improper deductions can destroy the exemption for entire classes of employees, which is why the file checks deduction practice and the safe-harbor policy alongside duties.
We found a misclassified position. Now what?
Don't just flip the switch. Quantify the look-back exposure, decide the correction approach with advice, and plan the transition — timekeeping, overtime budgeting, and honest communication. Abrupt, unexplained reclassification is what prompts employees to ask about the past.
Disclaimer. This resource is provided for general employer education and planning purposes. It is not legal advice and does not create an attorney-client relationship. Employment laws, agency guidance, and local requirements may change. Employers should review the facts of each situation before acting and consult appropriate HR or legal counsel when needed.