WASHINGTON, D.C. — The U.S. Department of Labor has issued four new opinion letters interpreting federal wage-and-hour law, providing guidance on overtime eligibility, bonus calculations, meal-break compensation, and pre-shift work requirements that affect employers and workers covered by the Fair Labor Standards Act.
The opinion letters, released by the department’s Wage and Hour Division, offer official interpretations of how the law applies to specific workplace scenarios and are intended to help employers and employees navigate compliance questions involving compensation and overtime rules.
Labor officials said the letters address recurring issues involving exempt employees, overtime calculations, compensable work time, and timekeeping practices.
One opinion letter examines whether employees classified as exempt under the Fair Labor Standards Act may perform separate hourly-paid work for the same employer and what overtime obligations may result.
Another addresses whether certain bonus structures satisfy federal overtime requirements when bonuses are calculated as a percentage of an employee’s total earnings.
The department also issued guidance on whether time spent traversing an employer’s premises during a meal break may qualify as compensable work time when employees remain on-site during a 30-minute meal period.
A fourth opinion letter evaluates whether certain pre-shift activities performed by hospital employees constitute compensable work and whether rounding clock-in times to scheduled shift start times complies with federal labor regulations.
“Opinion letters explain how the laws enforced by the division apply in specific situations and circumstances that are faced by employees, employers, and others every day across America,” Wage and Hour Division Administrator Andrew Rogers said. “The letters issued today explicate important and longstanding principles under the Fair Labor Standards Act, including compensable time, exemptions, and bonuses included in the regular rate of pay.”
The guidance marks the latest step in the department’s revived opinion letter program, which was relaunched in June 2025 as part of a broader effort to provide compliance assistance and clarify the application of federal labor laws.
Opinion letters are issued in response to specific requests from individuals, businesses, and organizations seeking guidance where existing regulations or prior interpretations may not clearly address a particular factual situation.
The department noted that while the letters address individual scenarios, they may also provide guidance to employers and workers facing similar circumstances.
The Wage and Hour Division maintains an online repository of opinion letters and accepts requests for future guidance at https://www.dol.gov/agencies/whd/opinion-letters/request.
Employers and workers seeking compliance assistance can also contact the division’s toll-free helpline at 866-4US-WAGE (487-9243).
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