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Part Three: You Can’t Contract Away Work Time – and Overtime Rules for Commissioned Employees

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n January 5, 2026, the U.S. Department of Labor’s Wage and Hour Division issued six opinion letters addressing a range of FMLA and FLSA issues. This post – part three of a three-part series – covers the final two letters, both under the FLSA, and both aimed at assumptions employers sometimes make about f

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exibility. One letter addresses whether mandatory pre-shift “roll-call” time can be excluded from overtime calculations based on

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