U.S. Department of Labor

Wage and Hour Division

November 2016
Table of Contents

Table of Contents

Table of Contents.......................................................................................................................... ii

TAB 1: AGENCY ORGANIZATIONAL OVERVIEW .......................................................................... 1

Mission........................................................................................................................................ 1

Authorizing Legislation .............................................................................................................. 1

Organizational Structure ............................................................................................................. 3

Organizational Changes During the Past Eight Years.............................................................. 10

Key Leaders.............................................................................................................................. 16

TAB 2: 30/60/90 DAYS – STATE OF PLAY.................................................................................... 17

Key Meetings, Decisions and Announcements ........................................................................ 17

Key Agency Stakeholders......................................................................................................... 17

TAB 3: INITIATIVES ..................................................................................................................... 19

Policy and Regulatory Issues.................................................................................................... 19

Major Grants and Contracts...................................................................................................... 19

Enforcement.............................................................................................................................. 19

Audits and Reports.................................................................................................................... 21

Management.............................................................................................................................. 21

Calendar.................................................................................................................................... 23

TAB 4: BUDGET ........................................................................................................................... 25

TAB 5: AGENCY PERFORMANCE................................................................................................. 27
TAB 1: Agency Organizational Overview

1

TAB 1: AGENCY ORGANIZATIONAL OVERVIEW

Mission

The Wage and Hour Division (WHD) mission is to “promote and achieve compliance with labor 

standards to protect and enhance the welfare of the Nation’s workforce.”

Authorizing Legislation

WHD is authorized to administer and enforce a variety of laws that establish the minimum 

standards for wages and working conditions in the United States. Collectively, these labor 

standards cover most private, state, and local government employment. These labor laws range 

from some of the earliest labor protections passed by Congress to some of the most recent. 

Although they differ in scope, all of the statutes enforced by WHD are intended to protect and to 

promote the welfare of the nation’s workforce, to provide opportunities for advancement, to 

ensure fair compensation for work performed, and to level the playing field for responsible 

employers. The Fair Labor Standards Act (FLSA) minimum wage provisions and the 

government contract prevailing wage laws provide a floor for the payment of fair wages, while 

the FLSA overtime provisions are intended to broaden work opportunities and promote 

employment. The Migrant and Seasonal Agricultural Worker Protection Act (MSPA) and the 

immigration programs establish working conditions intended to protect the wages and the safety 

and health of vulnerable workers, to ensure that the local labor force is not displaced by lower 

paid foreign or migrant labor, and ensure employers that obey the law are not disadvantaged. The 

McNamara-O’Hara Service Contract Act (SCA) requires contractors and subcontractors 

performing services on prime contracts in excess of $2,500 to pay service employees in various 

classes no less than the wage rates and fringe benefits found prevailing in the locality, or the 

rates (including prospective increases) contained in a predecessor contractor's collective 

bargaining agreement. The Davis-Bacon and Related Acts (DBRA) require payment of 

prevailing wages on federal funded or assisted construction projects. The Family and Medical 

Leave Act (FMLA) was enacted to help workers balance family and work responsibilities and 

help keep middle class families in the middle class by providing job protection, and the child 

labor provisions of the FLSA ensure the safe employment of young workers, encourage their 

educational endeavors, and provide a path to future employment.

Public Law / Act Legislation Statute No. / US Code

PUB. L. 75-718 Fair Labor Standards Act of 1938, as 

amended. 29 U.S.C. 201-219

PUB. L. 74-846 Walsh-Healey Public Contracts Act, as 

amended. (1936). 41 U.S.C. 6501-6511

PUB. L. 90-321 Consumer Credit Protection Act(Title III –

Restriction on Garnishment). (1968). 15 U.S.C. 1671-1677

PUB. L. 87-581 Contract Work Hours and Safety 

Standards Act, as amended. (1962). 40 U.S.C. 3701-3708

PUB. L. 89-286 McNamara-O’Hara Service Contract Act, 

as amended. (1965). 41 U.S.C. 6701-6707

PUB. L. 71-798 Davis-Bacon Act, as amended and related 40 U.S.C. 3141-3148
TAB 1: Agency Organizational Overview

2

Public Law / Act Legislation Statute No. / US Code

acts. (1931).

PUB. L. 97-470 Migrant and Seasonal Agricultural Worker 

Protection Act. (1983) 29 U.S.C. 1801-1872

PUB. L. 99-603

PUB. L. 101-649

Immigration and Nationality Act, as 

amended by the Immigration Reform and 

Control Act.

8 U.S.C. 1101(a)(15)(E), (H), 

1184(c), 1324b; 29 U.S.C. 1802, 

1813(a)

PUB. L. 100-347 Employee Polygraph Protection Act 

(1988). 29 U.S.C. 2001-2009

PUB. L. 103-3 Family and Medical Leave Act of 1993. 29 U.S.C. 2601-2654

PUB. L. 105-277

American Competitiveness and Workforce 

Improvement Act (ACWIA), Title IV of 

the Omnibus Consolidated and Emergency 

Supplemental Appropriation Act. (1998).

Pub. L. 105, Title IV, Sec. 414(b) 

and (c)

PUB. L. 108-447

L-1 Visa and H-1B Visa Reform Act, Title 

IV of the Consolidated Appropriations 

Act, (2005).

Pub. L. 108-447, Title IV, Sec. 

401-430

PUB. L. 89-209, 94-

462, and 99-164

National Foundation for the Arts and 

Humanities Act, as amended, Sections 

5(j), 5(k), 7(g), and 7(j). (1965).

20 U.S.C. 954 (m), (n) and 956 

(g), (j)
TAB 1: Agency Organizational Overview

3

Organizational Structure

On November, 8, 2009, the Employment Standards Administration (ESA) was abolished and the 

four major program components of ESA, including WHD, became stand-alone programs 

reporting directly to the Secretary of Labor. The purpose of the reorganization was to improve 

the efficiency of all four programs by eliminating a layer of review and decision-making, which 

allows DOL leadership to more quickly attend to policy matters in each program without having 

an added organization component review between the program heads and senior leadership.

As a result, WHD’s National Office was reorganized in 2010 into five primary organizational 

units headed by career senior executives. The Assistant Administrator for the Office of Policy, 

and the Assistant Administrator for the Office of Planning, Performance, Evaluation and 

Training report to the non-career Deputy Administrator, and the Assistant Administrator for 

Administrative Operations, the Assistant Administrator for Office of Government Contracts, and 

the five Regional Administrators report to the career Deputy Administrator for Program 

Operations. The National Office is comprised of approximately 190 staff, responsible for the 

functions detailed below. The remaining 1600 staff are distributed among the five regions and 

are principally located at the local level among the 55 district offices, and many associated area 

offices and field offices.
TAB 1: Agency Organizational Overview

4

Organizational Chart

Administrator

Dr. David Weil

(PAS)

Deputy Administrator for Program 

Operations

Patricia Davidson

(Career SES)

Assistant Administrator for 

Administrative Operations

Rachel Torres

(Career SES)

Northeast 

Regional Administrator

Mark Watson

(Career SES)

Assistant Administrator for 

Office of Government 

Contracts

Mike Lazzeri

(Career SES)

Western

Regional Administrator

Ruben Rosalez

(Career SES)

Southeast 

Regional Administrator

Wayne Kotowski

(Career SES)

Midwest

Regional Administrator

Karen Chaikin

(Career SES)

Southwest 

Regional Administrator

Betty Campbell

(Career SES)

Assistant Administrator for 

Office of Policy

Mary Ziegler

(Career SES)

Assistant Administrator for 

Office of Planning, Performance, 

Evaluation and Training

Ann Lichter

(Career SES)

Deputy Administrator

Laura Fortman

(Non-Career SES)

Chief of Staff

Tony Martinez

(Non-Career)

Senior Policy Advisor

Tonya Goldman

(Non-Career)

Senior Advisor

Laura Tatum

(Non-Career)

Senior Advisor

Becky Ogle

(Non-Career)

Senior Advisor

Joe McNearney

(Non-Career)

Policy Advisor

Samantha Sanders

(Non-Career)
TAB 1: Agency Organizational Overview

5

A. Deputy Administrator 

The non-career appointee who serves as WHD’s Deputy Administrator is responsible for policy

and regulatory work, strategic planning and performance management, learning and evaluation, 

data management, communications, stakeholder engagement, and business transformation 

efforts. The Deputy Administrator oversees the Office of Policy and the Office of Planning, 

Performance, Evaluation, and Training.

Office of Policy

The Office of Policy, headed by a SES assistant administrator, is responsible for developing and 

implementing the division’s legislative, regulatory, and enforcement policies. The Office has two 

divisions.

• The Division of Regulations, Legislation, and Interpretation is responsible for 

developing national policies, regulations, and interpretations under the laws administered 

and enforced by WHD. This Division is primarily responsible for the Field Operations 

Handbook and guidance, and works with the Division of Enforcement Policies and 

Procedures on the development of guidance and informational materials related to 

regulatory or statutory changes, Administrator Interpretations, Field Assistance Bulletins, 

and other guidance documents.

• The Division of Enforcement Policy and Procedures is responsible for developing and 

implementing enforcement policies and procedures. The Division is primarily responsible 

for the development of Administrator Interpretations, Field Assistance Bulletins, and 

other guidance documents, including Field Operations Handbook content, and works with 

the Division of Regulations, Legislation, and Interpretation on the development of 

regulations and related guidance and informational materials.

Office of Planning, Performance, Evaluation and Training

The Office of Planning, Performance, Evaluation and Training, headed by a SES assistant 

administrator, is responsible for strategic and operational planning, budget formulation, data 

management, performance management, research and evaluation, business transformation 

efforts, partnerships and stakeholder engagement, and communication and liaison activities. The 

Office is comprised of two distinct divisions.

• The Division of Communication is responsible for the agency’s internal and external 

communications, including communications with agency and department personnel, state 

and local governments, Congress, media, stakeholders, and workers. The Division also 

oversees stakeholder engagement at the national level and supports this work at the local 

level. 

• The Division of Strategic Planning and Performance (DSPP) is responsible for the 

budget formulation, development and implementation of performance measures, and 

reporting of performance outcomes. This Division provides national planning, direction 
TAB 1: Agency Organizational Overview

6

and coordination of the agency’s strategic enforcement initiatives. DSPP also sets the 

learning and evaluation program for the agency and has established a forensic accounting 

program to support back wage recovery. 

• The Chief Data Officer is responsible for establishing data governance practices to

manage and use data to support agency operations including data collection, analysis, 

business intelligence, and open data efforts.

Deputy Administrator’s Organization Chart

B. Deputy Administrator for Program Operations 

The career deputy administrator is responsible for all national and field program operations. 

This unit has offices for government contracts enforcement, prevailing wage generation and 

enforcement, enforcement strategy and support, and the administrative operations for both the 

national office and the regions.

• The Office of Administrative Operations is headed by a SES administrative officer. 

This unit includes: financial management and budget execution; training; business 

operations, including human resources and procurement; information technology; and 

documents/records management.

• The Division of Enforcement Strategy and Support is responsible for managing a 

nationwide accountability review program and developing enforcement and litigation 

strategies for targeted industries. 
TAB 1: Agency Organizational Overview

7

• The Office of Government Contracts is headed by a SES assistant administrator and is 

responsible for matters related to government contracts enforcement and wage 

determinations. The Office is comprised of two distinct units:

o The Branch of Government Contracts Enforcement administers and enforces the 

prevailing wage requirements of the Davis Bacon Act, the Service Contract Act, 

and other statutes and Executive Orders applicable to Federal contracts for 

construction and for the provision of goods and services, and 

o The Division of Wage Determinations determines the minimum compensation 

based upon locally prevailing wage rates and fringe benefits for employees 

performing work on contracts subject to SCA, DBRA, and other statutes 

applicable to Federal contracts for construction and for the provision of services.

• The five regional administrators from WHD’s five regions, the Northeast headquartered 

in Philadelphia, the Southeast headquartered in Atlanta, the Midwest headquartered in 

Chicago, the Southwest headquartered in Dallas, and the West headquartered in San 

Francisco, report to this deputy administrator.

Program Operations Organization Chart

Deputy Administrator for 

Program Operations

Patricia Davidson

Northeast Region

Division of 

Enforcement 

Strategy and 

Support

Erin DeByl

Office of 

Administrative 

Operations

Rachel Torres

Office of 

Information 

Technology

Thomas Flagg

Branch of Business 

Operations

Phyllis YatesManigault

Branch of Training 

and Education

Bonnie Barnish

Branch of Financial 

Management

Karen Gaskin

Branch of 

Documents 

Management

Steven Pierce

Office of 

Government 

Contracts

Mike Lazzeri

Branch of 

Government 

Contracts

Amy DeBisschop

Branch of Wage 

Determinations

Daniel Simms

Southeast Region

Midwest Region

Southwest Region

Western Region
TAB 1: Agency Organizational Overview

8

C. Wage and Hour Division Regional Structure

WHD consists of five regions, each headed by an SES regional administrator. The regional 

administrators are supported by deputy regional administrators, directors of enforcement and 

directors of operations. Additional regional office staff includes regional planning officers, wage 

determination personnel, back wage and civil money penalty collection and disbursement 

personnel, Freedom of Information Act specialists, and program enforcement coordinators. Each 

region has district offices and area offices that are headed by a manager, and field offices in 

which investigators are stationed. WHD investigators, technician, and assistants are stationed in 

the district and area offices. 

Northeast Regional Office

The Northeast has fourteen district offices headed by a district director and eleven area offices 

headed by an assistant district director. The Regional Office is located in Philadelphia, PA. 

Southeast Regional Office 

The Southeast Region has ten district offices and eleven area offices. The Regional Office is 

located in Atlanta, GA.

Midwest Regional Office 

The Midwest Region has nine district offices and seven area offices. The Regional Office is 

located in Chicago, IL. 

Southwest Regional Office 

The Southwest has twelve district offices and four area offices. The Regional Office is located in 

Dallas, TX. 

Western Regional Office 

The Western Region has ten district offices and six area offices. The Regional Office is located 

in San Francisco, CA. 
TAB 1: Agency Organizational Overview

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TAB 1: Agency Organizational Overview

10

Agency At-A-Glance
TAB 1: Agency Organizational Overview

11

Organizational Changes During the Past Eight Years

The Wage and House Division’s (WHD) mission is to “promote and achieve compliance with 

labor standards to protect and enhance the welfare of the Nation’s workforce.” With more than 

7.3 million establishments and 135 million workers covered by the laws we enforce, WHD has 

established a strategic enforcement approach to achieving compliance. To carry out the goal of 

protecting the earnings and welfare of workers, and ensuring a fair and level playing field for 

employers, WHD prioritizes and directs efforts to where the problems are largest, where workers 

are least likely to exercise their rights provided by the law, and where WHD can have the 

greatest impact on compliance.

Strategic enforcement is WHD’s response to an increasingly complex structure of employment 

and labor market. The 21st century workplace in many industries is no longer a traditional brick 

and mortar company owned and operated by a single employer. In recent years, the employment 

relationship between workers and businesses receiving the benefit of their labor has fissured 

apart as companies have contracted out or otherwise shed activities to be performed by other 

businesses. Often those secondary companies deepen the fissures, breaking those activities apart 

and shifting work even further out from the primary business. For example, when you walk into 

the lobby of a hotel these days operating under a well-known brand name, there’s a high 

probability that the workers who greet you at the desk or clean your room are likely not 

employed by the hotel chain of that corporate brand. Instead, the management of that hotel 

property has actually been contracted out to another business offering this service. In fact, many 

more of the services provided on site – cleaning companies, landscapers, food service providers, 

etc. – have also been contracted out to providers of these services. Employees are often unaware 

for whom they actually work.

The blurred lines from the fissured workplace make achieving compliance with the wage and 

hour laws a difficult task. Intense competition within business models like subcontracting, 

temporary agencies, labor brokers, franchising, licensing and third-party management leads to 

low pay, and noncompliance pulls down standards for all – making it difficult for responsible 

employers to survive in low margin, fiercely competitive conditions. The costs in this race to be 

the lowest bidder are borne by workers deprived of their wages and their rights and by lawabiding employers who are undercut by unscrupulous competitors.

WHD has achieved significant results over the last eight years through strategic enforcement. 

Strategic enforcement requires a proactive approach to using enforcement, outreach, and 

different forms of partnership to achieve compliance. Since the beginning of 2009, WHD 

investigations have resulted in nearly $1.6 billion in back wages for 1.7 million workers 

nationwide. In Fiscal Year 2015, WHD investigations resulted in more than $246 million in back 

wages and helped over 240,000 workers. Importantly, as WHD has implemented strategic 

enforcement, the average back wage recovery per worker has increased steadily, from $785

dollars in FY 2009 to over $1,000 per worker in FY 2015, a significant amount for the 

predominantly low-wage workers who benefit from WHD’s enforcement efforts. 

These results, described in more detail below, have been achieved by a sustained effort to 

maximize WHD’s impact on compliance through strategic enforcement. 
TAB 1: Agency Organizational Overview

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• Evidence-Based Approach: At its core, strategic enforcement means taking an evidencebased approach to determining where problems are the greatest, where workers are least 

likely to complain, and where WHD can have the greatest impact on compliance. WHD 

uses data to determine which industries are at highest-risk for non-compliance and 

prioritizes enforcement in these industries. WHD conducts the majority of investigations 

in priority industries that employ workers vulnerable to being subject to illegal labor 

practices. WHD also uses performance measures and evaluation studies to continually 

evaluate and learn about the effectiveness of the agency’s efforts. 

• Agency-Initiated Enforcement: A growing percentage of investigations are directed, i.e.,

agency-initiated, which allows the agency to carry out strategies that aim for industrylevel compliance. Whereas before WHD was more reactive and focused on resolving 

individual complaints, through strategic enforcement WHD proactively directs resources 

to where the evidence shows labor law violations are greatest. WHD also seeks to impact 

compliance beyond the investigated employer, so that enforcement actions resonate 

throughout a particular sector and influence the behaviors of employers across the entire 

industry, leveling the playing field for law-abiding businesses. 

• Effective Enforcement: WHD has rebuilt its number of investigators from 731 on board at 

the end of FY 2008 to 995 on board at the end of FY 2015, and is focused on changing 

incentives for compliance by using all enforcement tools available. When violations are 

found, WHD uses enforcement tools such as litigation, civil money penalties, liquidated 

damages, subpoenas, search warrants, hot goods, and debarment to recover back wages 

for the affected workers and deter future violations from occurring.

• Stakeholder Engagement and Communications: In order to expand its impact, WHD has 

strategically engaged stakeholders and used communications to promote compliance. 

Employers who are aware of their legal responsibilities (and the consequences of 

breaking the law) and workers who are aware of their rights are better positioned to 

identify and remedy violations, or to prevent them from occurring in the first place. Seen 

in this light, stakeholder engagement and outreach complement the agency’s enforcement 

activities. 
TAB 1: Agency Organizational Overview

13

WHD conducts the majority of investigations in priority industries that employ workers 

vulnerable to being subject to illegal labor practices. These industries include hotel and 

motel work, agriculture, janitorial services, garment manufacturing, and the restaurant 

industry. WHD is reaching those workers by devoting three-quarters of its investigations 

to priority industries (74 percent in fiscal year 2015). At the same time, a growing 

percentage of investigations are directed, i.e., agency-initiated, which allows the agency to 

carry out strategies that aim for industry-level compliance. In fiscal year 2015, more than 

42% of WHD investigations were agency-initiated, up from 35% just 6 years ago.

Whereas before WHD was more reactive and focused on resolving individual complaints, 

through strategic enforcement WHD proactively directs resources to where the evidence 

shows labor law violations are greatest. 

And it’s working. The Division’s directed investigations are smarter and more efficient –

and uncovering violations at nearly the same rate as its complaint-driven investigations. 

By fiscal year 2015, the percent of directed investigations without violations decreased to 

21 percent – versus 18 percent in complaint cases – which means the directed 

investigations are nearly as accurate as complaints in finding violations. 

Source: WHD website: Enforcement Statistics
TAB 1: Agency Organizational Overview

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As strategic enforcement has made investigations more effective at finding violations, the 

average amount of back wages per employee paid in violation continues to increase. In 

fiscal year 2015, the Wage and Hour Division’s compliance actions resulted in over $1,000 

in back wages per employee paid in violation – a roughly 30 percent increase over fiscal 

year 2009. Between 2010 and 2011, total back wages increased from $176 million to over 

$224 million. That trajectory continued in fiscal year 2015, when the agency found over 

$240 million in back wages.

It is important to place these annual back wage amounts into context. An average of more 

than $1,000 per worker is real money that has enabled them to put food on the table, cover 

the rent, provide care of their children, keep the lights on and pay for other expenses. These 

results illustrate the real-world, life-changing effects and benefits of WHD’s work.
TAB 1: Agency Organizational Overview

15

Stakeholder Engagement and Strategic Communications

Strategic communication provides a powerful and necessary complement to enforcement. 

Outreach, media, and educational efforts enable WHD to deter future violations among the 

regulated community and educate workers of their rights under the laws enforced by WHD, by 

strategically messaging enforcement outcomes and addressing compliance topics of interest to 

WHD’s broad community of stakeholders. The Community Outreach and Resource Planning 

Specialist (CORPS) position, which was established in FY 2011, plays an important role in 

carrying out these strategies and in supporting strategic enforcement planning at the local level. 

WHD’s Misclassification Initiative is making great strides in combating a pervasive issue, where 

employees, misclassified as independent contractors, are denied access to critical benefits and 

protections – such as family and medical leave, overtime compensation, minimum wage pay and 

Unemployment Insurance. Employee misclassification generates losses to the U.S. Treasury and 

the Social Security and Medicare funds. Misclassification also creates a serious competitive 

disadvantage for employers who comply with the law. WHD has signed Memorandums of 

Understanding with the IRS, and with labor commissioners and other agency leaders 

representing 35 state governments with more under development. These MOUs are enabling the 

Department to share information and to coordinate enforcement efforts with participating states 

and agencies in order to level the playing field for law-abiding employers and to ensure that 

employees receive the protections to which they are entitled under federal and state law. These 

collaborations are making a difference, including generating lost revenue for states. WHD 

regularly finds large concentrations of misclassified workers in low-wage industries. In Fiscal 

Year 2015, WHD investigations resulted in more than $74.3 million in back wages for more than 

102,000 workers in industries such as janitorial, food service, temporary staffing, day care, 

hospitality and garment. As part of the initiative, WHD issued an Administrator’s Interpretation

to provide employers assistance in complying with the law.

WHD is committed to increasing public awareness and compliance with federal wage and hour 

laws. Since 2009, WHD has conducted more than 15,000 outreach events and presentations, 

providing valuable information and compliance assistance to thousands of employees, 

employers, community organizations, industry associations and other stakeholders nationwide. 

WHD also offers a number of useful compliance resources intended to provide employers with 

readily accessible, easy-to-understand information relevant to both their rights and to their 

responsibilities under the law. To achieve a more ongoing presence in communities, the Division 

is seeing results from its newly hired Community Outreach and Resource Planning Specialists to 

work in many WHD District Offices. These officers are establishing and maintaining lines of 

communication at the local level; engaging partners in dialogue about local industry practices 

and labor concerns; providing training and resources to advocates, employer associations, and 

other stakeholders on wage and hour laws; and providing WHD with recommendations on how 

to better serve workers and their communities.

Updating a Fair Day’s Pay 

WHD’s regulatory priorities reflect the agency’s commitment to ensuring the protections we 

enforce are relevant to today’s workplace and workforce. DOL has also focused on the 
TAB 1: Agency Organizational Overview

16

implementation of its regulations, striving to ensure that WHD investigators are well-trained and 

the regulated community is well-informed.

• WHD is implementing two regulatory actions that had an effective date of January 1, 

2015: the Minimum Wage and Overtime Pay Rule for Direct Care Workers (the Home 

Care Final Rule); and the Minimum Wage for Contractors Final Rule which implemented 

Executive Order 13658 and raised the minimum wage for work performed by parties who 

contract with the Federal Government to $10.20.

• WHD refined requirements and implementation strategies for Executive Order 13673 –

Fair and Pay and Safe Workplaces which creates a system for taking into account a 

prospective contractor’s labor law compliance record in making contract decisions. 

• In May 2016, WHD issued a final rule to update and revise the regulations issued under 

the FLSA implementing the exemption from minimum wage and overtime pay for 

executive, administrative, professional, outside sales, and computer employees. This 

exemption is referred to as the FLSA's "EAP'' or "white collar'' exemption. To be 

considered exempt, employees must meet certain minimum tests related to their primary 

job duties and be paid on a salary basis at not less than a specified minimum amount. The 

overtime final rules becomes effective December 1, 2016, raising the salary threshold 

indicating eligibility from $455/week to $913 ($47,476 per year), ensuring protections to 

4.2 million workers.

• In September 2016, WHD published a final rule to implement Executive Order 13706, 

Establishing Paid Sick Leave for Federal Contractors. The Executive Order requires 

certain employers that contract with the federal government to provide their employees 

with up to seven days of paid sick leave annually, including for family care and absences 

resulting from domestic violence, sexual assault, and stalking.

• WHD has also focused efforts for government contract workers. In the past two years, 

WHD has taken a number of actions to improve the Davis-Bacon construction survey 

process. In 2015, WHD conducted a comprehensive evaluation of the wage determination 

process to identify continuing issues and develop additional process improvements to 

enhance the accuracy and timeliness of wage rates. WHD has provided transparency into 

the program’s operations by building key stakeholder relationships and seeking input, 

introducing mid and post survey briefings into the process so that contractors may 

understand the process and their role in ensuring that participation increases. In response 

to feedback from stakeholders, WHD has not only published a survey schedule for fiscal 

year 2016, but has also sought input from stakeholders on a proposed survey plan for 

fiscal year 2017.

• Internally, WHD has moved towards data driven decision-making, using project data to 

make targeted policy decisions and to select where and how to survey. WHD anticipates 

continuing positive results from many of these decisions in the next few years. 
TAB 2: 30/60/90 Days – State of Play

17

TAB 2: 30/60/90 DAYS – STATE OF PLAY

Key Meetings, Decisions and Announcements

In April or May of 2017, the agency will hold its annual Spring Executive Leadership Team 

meeting to set priorities for the upcoming fiscal year. 

Construction Surveys to Determine Wage Rates

Federally financed or assisted construction projects subject to the Davis-Bacon and related Acts 

(DBRA) must contain a prevailing wage determination. The agency has planned surveys to 

determine wage rates in the following areas:

Region Survey Type State

SW Building and Heavy (Metro Counties) New Mexico

NE Statewide Building Connecticut

NE Building (Select Counties) New York

W Statewide All Types Guam

NE Statewide Highway Virginia

SE Statewide Residential North Carolina

SE Statewide Residential South Carolina

SE Statewide Highway Alabama

MW Statewide Highway Kansas

W Statewide Residential Alaska

Key Agency Stakeholders

Stakeholders interested in WHD’s actions:

• American Payroll Association (APA)

• American Staffing Association (ASA)

• American Network of Community Options and Resources (ANCOR)

• Associated General Contractors (AGC)

• Associated Builders and Contractors, Inc. (ABC)

• Building and Construction Trades Department (BCTD)

• Ford Foundation

• HR Policy Association

• Interfaith Worker Justice (IWJ)

• Jobs With Justice

• National Alliance for Fair Contracting

• National Association of Home Builders (NAHB)
TAB 2: 30/60/90 Days – State of Play

18

• National Employment Law Project (NELP)

• Paraprofessional Healthcare Institute (PHI)

• Public Welfare Foundation

• College and University Professional Association for Human Resources (CUPA-HR)

• National Council of Nonprofits

Stakeholders that should be engaged by the Secretary in the first 90 days:

• American Federation of Labor and Congress of Industrial Organizations (AFL-CIO)

• Service Employees International Union (SEIU)

• Society for Human Resource Management (SHRM)

• U.S. Chamber of Commerce
TAB 3: Initiatives

19

TAB 3: INITIATIVES

Policy and Regulatory Issues 

Section 14(c) of the FLSA provides that the Secretary of Labor may, to the extent necessary to 

prevent the curtailment of opportunities for employment, issue certificates to permit the payment of 

subminimum wages to individuals with disabilities whose earring or productive capacities are 

affected by their disability. These regulations were last updated in 1989. 

Major Grants and Contracts - N/A

Enforcement 

With more than 7.3 million establishments and 135 million workers covered by the laws WHD 

enforces, the agency will never have enough resources. Through strategic enforcement, WHD seeks 

to impact compliance beyond the investigated employer, so that enforcement actions resonate 

throughout a particular sector and influence the behaviors of employers across the entire industry, 

leveling the playing field for law-abiding businesses. 

While the strategy is efficient and deliberate, WHD’s tools based on prior enforcement models, 

which generally involved resolutions at the employee level only, are out of date. WHD’s focus is to 

achieve system-wide impacts on employers that go beyond a single investigated establishment. This 

requires a more in-depth understanding of industries, business models, and a more coordinated 

approach to conducting enforcement across networks of businesses, supply chains, or contracting 

relationships. As a result, the agency confronts the limitations of working with technology, 

operations, and systems built for a different era. To confront this reality, WHD is aligning its

infrastructure to current strategies, significantly advancing the agency’s ability to achieve the goals 

of strategic enforcement.

Enforcement alone is not the answer to the nation’s compliance challenges. While WHD is 

committed to strategic enforcement, the agency is also updating and modernizing its approach to 

compliance assistance. Increasing compliance requires providing employers the information they 

need to operate in accordance with labor laws. Employers who are aware of their legal 

responsibilities (and the consequences of breaking the law) and workers who are aware of their 

rights are better positioned to identify and remedy violations, or to prevent them from occurring in 

the first place. While the agency continues to improve its public-facing website and enforcement 

database, WHD is also identifying ways to make its administrative data and information more 

accessible and usable to the public, employers, employees, journalists, developers, stakeholders, 

and the research community. Results of all of WHD investigations are available in an online 

database, allowing, for instance, businesses to monitor the compliance of those in their supply 

chains, and consumers to make more informed decisions about where to spend their dollars. This 

type of transparency increases the incentive for employers to maintain compliance.
TAB 3: Initiatives

20

WHD also conducts directed investigations to secure compliance for other workers at a higher risk 

of exploitation such as: workers with disabilities, young workers, agricultural workers, and workers 

with no private right to pursue remedies on their own behalf. Enforcing the law is key to protecting 

workers who deserve a fair day’s pay for a day’s work, for leveling the playing field for responsible 

employers, and for protecting fair and vigorous competition—the cornerstone of a strong economy.

WHD will continue refining and strengthening its strategies in priority industries with an emphasis 

on detecting the various forms of misclassification found in today’s workplaces, where workplace 

arrangements and business structures are more complex.

Addressing the Fissured Workplace: WHD is modernizing its approach in key enforcement areas 

in industries where complex employment relationships exist. Through directed investigations, 

WHD increases its presence in high risk industries, such as those industries with high minimum 

wage and overtime violations that employ vulnerable worker populations particularly those who do 

not typically report violations, either because they fear retaliation or because they do not understand 

the law and complaint process. WHD will continue to focus on industries characterized by a high 

degree of subcontracting, use of temporary labor providers, and other third-party managers. These 

industries are often fiercely competitive and, unfortunately, that can lead some unscrupulous 

employers to cut corners in an effort to gain a competitive advantage over employers who follow 

the law and protect their workers. If laws are not vigorously enforced, more and more employers 

can start to violate worker protection laws in an effort not to be under-bid. This results in a growing 

population of workers subject to illegal practices, including workers who are misclassified or who 

do not receive the wages they earned and were required to be paid by law. 

Enforcing the law is key to protecting workers who deserve a fair day’s pay for a day’s work, but 

these actions also protect fair and vigorous competition that is the cornerstone of a strong economy.

Agriculture: Domestic and temporary non-immigrant agricultural workers too often endure low 

wages, unsafe housing and transportation, and harsh working conditions that do not comply with 

the law. WHD will continue to develop the supply-chain based approach to enforcement, creating 

incentives higher up in the chain to compel compliance and change behaviors at all of the levels 

below. To support these efforts, WHD is developing an approach that accounts for the severity of 

the violations in its enforcement decision-making. By enabling the use of more nuanced data that 

represents the severity of violations, WHD will be better situated to make data-driven decisions to 

inform where to put our investigation resources and the development of strategies around supply 

chains and crops. By focusing on more severe violations, WHD will level the playing field within 

the industry to ensure that the worst violators are not gaining unfair and unwarranted advantages by 

their unlawful behavior. WHD is also committed to making its agriculture enforcement data, 

including data related to Farm Labor Contractors, more accessible and usable online so that it can 

be more effectively used by employers, buyers, and stakeholders seeking to ensure compliance 

within particular crops and supply chains. 

FMLA: In order to promote work and family balance, WHD will continue implementing its FMLA 

enforcement strategy to promote a more comprehensive approach to compliance. Since FMLA 

compliance at the establishment level is often driven by corporate policies, WHD has been

developing strategies to provide a more in-depth review of the employer’s business practices and 
TAB 3: Initiatives

21

leave policies with the objective of making a broader impact on compliance, rather than resolving 

one individual complaint. 

Section 14(c): On July 22, 2014, the President signed the Workforce Innovation and Opportunity 

Act (WIOA) which provides for comprehensive changes to employment for trainees and workers 

with disabilities. Among other items, WIOA amends the Rehabilitation Act of 1973 by establishing 

further requirements on conditions where workers with disabilities can be employed at 

subminimum wages. WIOA created an advisory committee to look broadly at increasing 

opportunities for competitive, integrated employment, as well as to examine the Section 14(c) 

program under the FLSA. 

Audits and Reports - Wage and Hour Division Needs to Strengthen Management Controls for Back Wage 

Distributions, Report No. 04-15-001-04-420 (March 31, 2015). 

Open Recommendations: Two out of three recommendations are in resolved status, which 

means further action is required before the OIG closes the recommendation. 

• Recommendation 1: To develop reporting tools that will support greater oversight 

and performance management of the back wage follow-up and distribution process. 

Due: September 30, 2016.

• Recommendation 3: Update the Field Operations Handbook and establish uniform 

procedures for staff to utilize all existing available tools and resources for locating 

employees due back wages. Due: December 31, 2016.

WHD is continuing to work on recommendations from the following report, which pre-dates FY 

2013.

- WHD Lacked Effective Financial Management of Back Wage and Civil Monetary 

Penalty Receivables, Report No. 22-12-013-04-420 (September 28, 2012).

WHD intends to close the following recommendations concurrent with efforts to address the 

above 2015 report on back wage distributions.

• Develop and implement policies and procedures to account and report status of back 

wage and civil monetary penalties

• Improve monitoring of work performed by contractors to ensure accuracy and 

completeness

• Update agency policies regarding segregation of duties

• Modify user guides for back wage and civil monetary systems to include reports 

used in the Treasury Report on Receivables (TROR) process.

Management 

IT Opportunities/Challenges

The Wage and Hour Division (WHD) has one central IT challenge and several IT opportunities. 

The challenge is WHD’s legacy IT system. The agency’s aging legacy IT system was recently 

reported to the Government Accountability Office as one of the Department of Labor’s top three 

mission critical legacy systems in need of the replacement. 
TAB 3: Initiatives

22

The agency has a plan in place for modernization and replacement, but without sufficient funding, it 

cannot implement the plan. Repeated requests in the President’s Budget for dedicated funding have 

not succeeded. Despite the lack of resources dedicated to this effort and consistent with best 

practices in modernizing IT, WHD regularly updates its systems in an iterative, modular way, in 

order to try to keep pace with the regulated community. At the same time, WHD is leveraging more 

modern development practices, such as lean start-up, agile, and human-centered design 

methodologies consistent with the Digital Services Playbook. Yet every year that passes without 

sufficient funding increases the likelihood that WHD’s legacy system will no longer be able to 

support the agency’s core programmatic needs. 

In the near term, WHD is focused on providing updated tools to its enforcement staff and the 

public. WHD has partnered with GSA’s 18F to bring modern practices, including agile 

development, lean start-up, and human-centered design, to its efforts to update and transform 

services and products. For example, WHD is converting its paper-based Field Operations 

Handbook (FOH) to a digital-native format. When finished, the Digital FOH will be an accessible, 

accurate, and easy to navigate resource that will efficiently facilitate research of WHD regulatory 

interpretations, enforcement policies, and administrative procedures. In addition, WHD is 

partnering with 18F and a developer to create a new online certification module for 14(c) certificate 

holders. This new module is being developed under GSA’s agile development blanket purchase 

agreement and represents one of the first agile development projects in the department. 

WHD is also focused on IT opportunities such as the agency’s investment in data infrastructure to 

support a more robust business intelligence platform, as part of a broader effort to build WHD’s 

data capacity. Data is the link between the agency’s mission and the technology necessary to 

accomplish the mission. The business strategy and goals drive the data strategy which informs the 

IT choices for infrastructure and applications. Delivering new data-driven applications and tools to 

the field positions the agency to adopt forward-looking technology and set the stage for further 

modernization. By making WHD’s data more accessible and visible to the public, external 

stakeholders such as industry leaders, employers, workers, and other government agencies can 

leverage WHD’s data to inform decisions and actions that influence compliance. 

Employee Engagement

WHD is working to improve employee engagement through the implementation of its Employee 

Viewpoint Survey Plan. Like all federal agencies, WHD receives annual results from the Federal 

Employee Viewpoint Survey (FEVS or EVS) that inform the development of a plan for 

improvement in the coming year. The challenges and solutions differ across the national office and 

WHD’s five regions; each office is leading individualized efforts under their Employee 

Engagement Plans. In the national office, leadership paid careful attention to the process for 

developing meaningful plans that reflect the views and ideas of the workforce. In FY 2015 and 

2016, the WHD Administrator convened a series of all-hands meetings to discuss the EVS findings 

and to engage employees in developing strategies to address areas for improvement. The National 

Office and the Western Region have also been participating in the pilot of the Modern Government 

Management Traits initiative that is based on a program instituted at Google. The initiative focuses 

on front-line managers who have the most influence on the day-to-day morale of the staff. The 

program involves action items that embody eight traits identified by Google of excellent managers. 
TAB 3: Initiatives

23

The agency is also developing professional, management, and leadership development programs for 

staff. 

In FY 2017, WHD will continue its collaborative processes, based on the principles of 

inclusiveness, transparency, and, most of all, engagement of employees at all levels. Regional 

offices have undertaken a range of efforts, including working with the National Council of Field 

Labor Locals to establish Labor/Management Teams in district offices, developing engagement 

competencies in local offices, participation in online training that provides steps for improving 

employee engagement through Appreciation, Communication and Empowerment, creating 

workplace principles for civility and communications, and the development of employee 

recognition programs.

Calendar

WHD enforcement and operations activities follow the fiscal year cycle, October 1 to September 

30th.

Each year, the Executive Leadership Team, which consists of the Administrator’s political staff, the 

Regional and Deputy Regional Directors and the Senior Executive Service Staff in the National 

Office, gathers input from each WHD functional area to set the priorities for the coming fiscal year, 

consistent with the Department’s strategic plan. This step usually occurs in April through June with 

the development of a draft plan that outlines how the agency plans to achieve the mission in the 

upcoming year. The framework is communicated through the Regional Office to the District Office

Managers in early summer typically. District Offices meet during the summer with their staff to 

develop strategies and local initiatives in support of the plan. The District Offices communicate 

their local plans through the Regional Office to the National Office for review and modification, as 

appropriate, in August. The Administrator then finalizes the plan after consultation in the DOL and 

approves local initiatives by the end of the fiscal year.
TAB 3: Initiatives

24

There are typically Executive Leadership Team meetings in the fall, winter, and spring. Training 

activities, accountability reviews, and prevailing wage surveys occur throughout the fiscal year. 
TAB 4: Budget

25

TAB 4: BUDGET

(Dollars in millions)

FY 2013

Enacted

FY 2014

Enacted

FY 2015

Enacted

FY 2016

Enacted

FY 2017

Request

Budget Authority $215.2 $224.3 $227.5 $227.5 $276.6

FTE 1,479 1,332 1,367 1,357 1,694

At-A-Glance

• WHD receives funding through an annual appropriation. In addition, WHD receives 

funding for its H-1B L-Fraud account through collected fees. The H-1B account supports 

additional FTE not included in the table above. In FY 2016, WHD apportioned $58.0

million to support 367 FTE through its H-1B account. A portion of H-1B funds are 

allocated to the Office of the Solicitor ($7.6 million in FY16).

Budget and FTE Trends

• In FY 2010, WHD received an increase of approximately $34.0 million over its FY 2009 

funding level for an appropriated funding level of $227.3 million. Since then, with the 

exception of FY 2013, the agency’s enacted funding levels have remained flat; the FY 2016 

appropriated funding is $227.5 million. In FY 2013, WHD was subject to the sequester and 

funded at $215.2 million. The FY 2017 President’s Budget requests approximately $45.0

million in additional resources, the majority of which would fund an increase in 

enforcement staff. WHD has included this request in previous President’s Budgets, but has 

not received an increased appropriation.

• WHD’s overall FTE usage increased in FY 2010 with the increased funding level. FTE 

usage continued to increase through FY 2012, when WHD used 1,810 FTE between its S&E 

and H-1B accounts. FTE usage began to decrease in FY 2013 due to sequestration, and this 

trend continued through FY 2015 due to flat funding levels and higher-than-expected 

attrition levels. The FY 2017 request includes an increase of over 300 FTE to support its 

strategic enforcement approach. As discussed above, WHD has included this request in 

previous President’s Budgets, but has not received an increased appropriation.

• In FY 2009 and 2010, WHD received approximately $15.0 million total in transferred 

funding for the American Recovery and Reinvestment Act from the worker protection pool. 

In FY 2013, WHD received $1.0 million in supplemental funding for the Superstorm Sandy 

Supplemental in order to cover travel costs to the Northeast region for national office staff 

to perform outreach activities and enforcement. 

• In FY 2013, WHD reduced contracts usage to achieve savings for sequestration. The 

agency also implemented a temporary hiring freeze, eliminated performance bonuses, 

reduced overtime and premium pay, and reduced PCS moves to reach the necessary funding 

level under sequestration. 

• Since FY 2014, WHD has requested $5.8 million to fund the IT modernization/legacy 

system replacement, but has not received an increased appropriation.

• Since FY 2009, WHD has increased its investigator staff, going from 743 investigator FTE 

in FY 2009 to over 900 investigator FTE in FY 2015 between the S&E and H-1B accounts. 

During this timeframe, WHD has significantly changed how it carries out the agency 
TAB 4: Budget

26

mission by adopting a strategic enforcement approach to achieving compliance. The agency 

has requested additional resources for investigator FTE in recent budget submissions to 

support its strategic enforcement approach; however, Congress has not provided this 

increase in resources. The FY 2017 President’s Budget again includes requests to support 

its push towards a more strategic enforcement, totaling approximately $30.0 million and 

over 300 FTE. 
TAB 5: Agency Performance

27

TAB 5: AGENCY PERFORMANCE

In FY 2010, WHD adopted a strategic enforcement approach to maximize the impact of its efforts 

by increasing the percent of directed (agency-initiated) investigations. WHD prioritizes efforts in 

industries where the problems are greatest, where 

workers are least likely to complain, and where 

WHD can influence compliance at the industrylevel. WHD has shifted its approach from focusing

on single establishments and resolving complaints 

to improving compliance across industries for 

greater numbers of workers. To measure success in 

targeting, the agency measures the “no violation 

rate” of its closed investigations. 

*Target reached (Y), 

Improved (I), or Not 

Reached (N)

FY/PY 

2011

FY/PY 

2012

FY/PY 

2013

FY/PY 

2014

FY/PY

2015

FY/PY

2016

FY/PY

2017

What 

Worked

 

What Didn't 

Work

 

Program Performance 

Improvement Plan 

Number of 

compliance actions

Target 31,897 34,533 34,231 33,635 30,500 30,500 31,411 WHD 

continued to 

prioritize 

compliance 

actions, both 

complaint 

and directed, 

in industries 

with high 

violations 

and 

vulnerable

workers.

WHD 

continued to 

identify areas 

where the 

infrastructure 

needed 

further 

alignment 

with 

strategies.

WHD will maintain 

optimal investigator 

levels to ensure 

productivity while 

advancing strategic 

enforcement goals 

through planning, 

coordination, and 

evaluation.

Result 33,293 34,139 33,146 29,483 27,915 -- --

Status Y I N N N -- --

Percent of directed 

investigations 

(excludes 

conciliations)

Target 32% 35% 38% 40% 43% 45% 46% WHD's 

enforcement 

program has 

evolved from 

complaintbased to 

strategic 

where 

directed 

investigations 

are 

conducted in 

priority 

industries 

and the 

complaints 

are 

prioritized.

WHD 

identified 

various ways 

the field can 

be further 

supported in 

their efforts to 

advance 

strategic 

initiatives.

WHD is 

implementing new 

tools and training to 

better equip the field 

with data and 

guidance

Result 29% 41% 44% 44% 42% -- --

Status -- Y Y Y N -- --

Percent of directed 

no violation cases

Target 28% 25% 23% 22% 25% 24% 22% WHD 

achieved the 

No violation 

rates provide 

WHD is piloting 

Result internal measures to 30% 29% 26% 22% 21% -- --

Performance Goal WHD 3.3 – Provide 

that vulnerable workers are employed

in compliance and secure sustained and 

verifiable employer compliance,

particularly among the most persistent 

violators.
TAB 5: Agency Performance

28

*Target reached (Y), 

Improved (I), or Not 

Reached (N)

FY/PY 

2011

FY/PY 

2012

FY/PY 

2013

FY/PY 

2014

FY/PY

2015

FY/PY

2016

FY/PY

2017

What 

Worked

 

What Didn't 

Work

 

Program Performance 

Improvement Plan 

Status -- I I Y Y -- --

lowest no 

violation rate 

in recent

history with a 

continued 

shift towards 

strategic 

enforcement 

in priority 

industries.

limited 

insights on 

the severity of 

violations.

evaluate the nature 

and severity of 

violations.

Percent of 

complaint no 

violation cases

Target 15% 23% 22% 20% 21% 21% 21% WHD 

maintained 

targeted 

complaint 

levels 

through 

prioritization 

and 

leveraged 

opportunities 

for strategic 

enforcement.

WHD

continued to 

balance the 

goals of 

strategic 

directed 

enforcement 

and customer 

service in 

States with 

limited 

enforcement.

See Above

Result 25% 21% 21% 19% 18% -- --

Status -- Y Y Y Y -- --

Percent of Directed 

Investigations in 

Priority Industries

Target 80% 83% 85% 86% 84% 84% 86%

WHD 

continues to 

place high 

priority and 

resources in 

industries 

with 

vulnerable 

workers 

unlikely to 

complain.

WHD may 

have reached 

the optimum 

level and is 

evaluating 

what other 

measures are 

needed to 

drive 

continued 

improvements 

that can be 

achieved.

WHD is developing 

methods and practices 

to further develop 

data on priority 

industries.

Result 82% 85% 83% 82% 84% -- --

Status Y Y N N Y -- --

Percent of 

complaint 

investigations in 

priority industries 

(excludes 

conciliations)

Target 63% 66% 68% 68% 69% 69% 70% WHD 

commits to 

industries 

where it 

expects to 

find 

vulnerable 

workers, 

which is 

balanced 

against doing 

investigations 

in each 

statutory 

program.

See Above See Above

Result 66% 67% 68% 67% 67% -- --

Status Y Y Y N N -- --

Average age of Target 40[p] 36[p] 36[p] 36[p] -- 45[p] 45[p] WHD has While the WHD is identifying 
TAB 5: Agency Performance

29

*Target reached (Y), 

Improved (I), or Not 

Reached (N)

FY/PY 

2011

FY/PY 

2012

FY/PY 

2013

FY/PY 

2014

FY/PY

2015

FY/PY

2016

FY/PY

2017

What 

Worked

 

What Didn't 

Work

 

Program Performance 

Improvement Plan 

Davis-Bacon wage 

rates for nonResidential 

Construction (in

months)

Result 39 39 42 43 46 -- -- shifted this 

program to a 

more datadriven 

approach to 

determine 

where to 

survey and 

how to 

identify 

where policy 

changes are 

needed.

measure 

tracks 

timeliness in 

completing 

surveys, the 

measure does 

not 

adequately 

reflect survey 

quality or 

accuracy.

areas to enhance the 

accuracy and 

timeliness of wage 

rates. WHD is 

working on additional 

improvements to 

shorten the time to 

complete surveys and 

simplify the data 

submission process

Status -- -- -- -- -- -- --

Sources: Wage Determination Generation System (WDGS) Wage and Hour Investigative Support and Reporting 

Database (WHISARD). Notes: WHD intends to replace the wage survey measure with one or more measures that 

better reflect the direction of the program. In the interim, WHD continues to report data from the survey measure 

without setting targets. The measure is not being used to drive performance, therefore, target-setting is not appropriate. 

The Family and Medical Leave Act (FMLA) entitles eligible employees of covered employers to 

take unpaid, job-protected leave for specified 

family and medical reasons with continuation of 

group health insurance coverage under the same 

terms and conditions as if the employee had not 

taken leave. WHD protects workers’ rights by 

conducting investigations into potential FMLA 

violations; performance is measured by timely 

resolution of incoming complaints.

65% 62%

74% 76%

73% 70% 72%

0%

20%

40%

60%

80%

100%

2009 2010 2011 2012 2013 2014 2015

Percent

Fiscal Year

Percent of FMLA Incoming Complaints Resolved within the Fiscal Year

Performance Goal WHD 3.2 –

Increase corporate compliance with the 

Family and

Medical Leave Act