Spring Edition 2016
Celebration of the
CENTURY In this
Issue
Dawn Sweeney, NRA President & CEO Keynote Address Pg. 12
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INSIDE THIS ISSUE 6
16
21
MRA Executive Officers Chairman, Bob Luke Rib Crib BBQ President, Buddy Lahl Kingswood Senior Living Community Vice-President, John LaRocca University Club of Missouri University Secretary / Treasurer, Herman Styles Colton’s Steakhouse MRA Executive Team
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2016 MRA President
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Attracting the Right Talent to Supercharge Performance
11 12
Dawn Sweeney, NRA President & CEO Keynote Address
16 19 21
The Celebration of the Century
Celebration of the
in thiS
issUe
Dawn Sweeney, nRa PReSiDent & CeO KeynOte aDDReSS Pg. 12
Executive Director GKCRA, Bill Teel
Missouri Restaurant Association 1810 Craig Road, Suite 225 St. Louis, MO 63146 Phone 314.576.2777 | Fax 314.576.2999 morestaurants.org
Restaurants Give Back Brace Yourself! What to Expect With the Proposed New Federal Wage and Overtime Rules
ON THE COVER
CentUrY
Director of Operations, Barb Hergenroether
Southwest Regional Director, Shelli Luke
MRA Riddle
Spring Edition 2016
CEO, Bob Bonney
James Eddy, 2016 Greater Kansas City Restaurant Association President, raises a glass to the storied history and rich future of the GKCRA. In his inaugural address, he provided a compelling example of the importance of a restaurant job in the life of a young American and tugged on the heartstrings of many of the nearly 1,200 in attendance to celebrate GKCRA’s Centennial Anniversary in January. A third-generation restaurateur, James is the third member of his family to serve as president of GKCRA.
Letters are welcomed, but must be signed to be considered for publication. Please include contact information for verification. Reproduction of articles appearing in Missouri Restaurant Magazine are authorized for personal use only, with credit given to Missouri Restaurant Magazine and/or the Missouri Restaurant Association. Articles written by outside authors do not necessarily reflect the views or positions of the Missouri Restaurant Association, its Board of Directors, staff or members. Products and services advertised in Missouri Restaurant Magazine are not necessarily endorsed by the MRA, and do not necessarily reflect the opinions of the MRA, its Board of Directors, staff or members. ADVERTISING INQUIRIES MAY BE DIRECTED TO: Missouri Restaurant Association Bob Bonney, CEO Mobile 636.432.9506 bbonney@morestaurants.org Barb Hergenroether, Director of Operations Office 314.576.2777 | Fax 314.576.2999 bhergenroether@morestaurants.org Missouri Restaurant Magazine is published quarterly for Association members. We welcome your comments and suggestions. Email: bbonney@ morestaurants.org
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morestaurants.org
MAY 2016
Feast delivers continuously updated culinary reporting.
Our 2016 President Buddy Lahl Brings Passion for Excellence and Unbridled Optimism MRA’s 2016 president will find a way to get things done; he was hard-wired that way early on. Born and raised in Quincy, Illinois, across the Mississippi River from Hannibal, Buddy Lahl’s earliest memories trace back to the kitchen of Doc’s Flame – the restaurant owned and operated by his grandparents, Bud and Agnes Lahl. It was there he first heard his grandmother’s admonition to “Do the very best you can” and “Everything you do needs to be a masterpiece.” Those words never left him. Buddy is among the 9 in 10 managers whose first job in the industry was an entry-level position. While in high school, he worked as a dishwasher and busboy at Stipp’s, a finedining restaurant in Quincy. His wages were $2.75 per hour. Before Stipp’s, he delivered daily newspapers on his bicycle for $7 a week. Through it all, he learned the value of hard work. After graduating from Quincy High School, Buddy moved to Kansas City to study electronics at DeVry Institute of Technology. Not owning a car, he found an apartment three blocks from school and applied for a job at a long-term care facility located between his apartment and DeVry.
2016 MRA President Buddy Lahl
When the dietary manager at Red Bridge Health Center told him no jobs were available, Buddy offered to wash dishes for free to prove himself. In short order, he was hired. Within two years, Buddy had progressed through the ranks of dietary aid, prep cook, line cook, assistant manager, and ultimately dietary manager. It was at Red Bridge that he met his future wife, Juanita, who was following a similar upward path in patient care. One climber found another. Buddy held forth at the facility for six years. In 1992, another opportunity found Buddy. Myron Green Corporation was just beginning to manage dining operations for long-term care facilities, and one of the first kitchens they operated was having difficulty with a state health inspection due to problems inherited from the previous regime. The nursing home was given 55 days to correct the deficiencies. The dining manager promptly resigned. The inspector recommended a young manager at Red Bridge to rectify the situation. Buddy’s career with Myron Green Corporation, which later became Treat America, began. He immediately knew he had hit the big time upon learning his new job came with a pager.
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MRA’s 2016 president will find a way to get things done; he was hard-wired that way early on. Buddy Lahl’s earliest memories trace back to the kitchen of Doc’s Flame – the restaurant owned and operated by his grandparents, Bud and Agnes Lahl.
Do the very best you can and everything you do needs to be a masterpiece.
morestaurants.org | MAY 2016
”
Buddy stayed with Myron Green-Treat America for 22 years, eventually becoming a regional director and overseeing more than 60 accounts. In 2014, he returned to the long-term care industry as Director of Dining Services at Kingswood Senior Living Community where he supervises a staff of 62. A board member of the Greater Kansas City Restaurant Association since 2006, and its president in 2011, Buddy’s early focus squared on education. As MRA’s president, government affairs is a priority. Other areas of emphasis during his presidency will be enhancing the ProStart School-to-Career program for educators and students through mentoring and industry work experience, as well as growing and engaging MRA’s membership. One lesson he has learned from his involvement in the legislative arena is that while restaurants compete for market share, they must collaborate for survival. Buddy and Juanita, along with their daughter, Natasha, and five grandchildren give back to their community by leveraging their love of horses to provide mentoring, education and goodwill to young people through the Show-me Riders, a non-profit horseback riding club. It’s important, the Lahl’s believe, to provide a shirt-tail for a youngster to hold on to. Juanita and her business partner recently opened an adult day-care facility to serve the elderly in the area. Still climbing. The Lahl’s make their home in Grandview. Given the force of his personality, his contagious optimism, and seemingly unlimited energy, folks tend to believe anything is possible when they are around Russell F. Lahl, IV. That is his name, but few know that. To us, he is Buddy – the guy who gets things done. Only a few are destined to be known by a single name. Rock & Roll had Elvis. Basketball had Michael. MRA has Buddy.
Buddy addresses the audience at the Centennial Anniversary and Inaugural Gala in Kansas City.
Bob Luke, 2015 MRA President with Buddy Lahl, 2016 MRA President.
The Missouri Restaurant Magazine
7
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ask the
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Attracting the Right Talent to Supercharge Performance By Rick Braa, CHAE
Q:
Recently, I’ve filled a few position openings that were vacant for quite some time. The people I’ve hired don’t seem to stick around and actually do more damage than good. With the labor pool tightening, what are the best ways to attract the right talent?
A:
Attracting the right talent is the highest priority in every business, yet the days of attracting plenty of candidates with passive hiring through the placement of a simple ad in the paper are long gone. A common complaint among operators is that there is little to no response for advertised positions, and companies using passive recruiting tactics find that the quality of candidates has also changed. Readily available candidates may have changed jobs frequently or may possess inadequate experience, talent or work ethic. To find talented employees who can supercharge your organization, consider the following: Advertise the position with the employee in mind. Employees want to make a difference and to work for a company that shares this commitment. Describe what your position offers the employee and how that benefits the company and community. If the position is a gateway to development, describe the development phases and benefits. Strong candidates are now looking for companies that stand out. Companies that take the time to craft an ad that speaks to the humanity of the candidate have the highest probability of a response. Use proactive recruiting tools. Many job boards today offer proactive recruiting tools that target both active and passive job seekers. Employees can post resumes on a job site such as indeed.com, and within moments of an employer posting a job opening, potential candidates will receive notice of a job matching key words on their resumes or listed as a priorities for their job search. These online job boards offer ease of application, and because candidates can answer several ads within minutes, they cast a wide net of opportunity. Use an applicant tracking system (ATS). An ATS allows tracking and filtering of resumes through online applications and screening questions. For example, if a job requires three years’ experience in a high-volume kitchen,
an applicant must agree whether he or she meets the criteria in advance of applying for a position. Unqualified applicants, recruiting services and spam are automatically filtered out. Added benefits of applicant tracking systems generally include onboarding and compliance tools to help you better navigate the time-consuming new hire and employee personnel management process. Offer an employee referral program. The best candidates come from employee referrals. Offer a meaningful reward, say $250 to $500 or more, when an employee refers a new hire who remains employed for at least six months. Statistically, most turnover happens within the first six months, so having an advocate and a system supporting retention is wise. This also adds an additional layer of employee engagement, that of bonding and being connected to co-workers. Employee-connected workforces are more highly engaged, produce better results and have less turnover. Move fast. There are currently more jobs than candidates. Until there is another recession, the job market is going to remain white hot. Candidates applying for a position may already be deep into the interviewing process with another company, so time is of the essence. Contact candidates, interview, and offer jobs quickly. The good candidates don’t last. By being proactive, organized and quick to hire, you’ll improve your recruiting process. Once the recruiting process is effective and streamlined, you’ll be able to replace unproductive and unengaged employees without fear while upgrading your staff to supercharge performance. For more information on improving profitability and driving sales, contact AMP Services at rbraa@ampservices.com. Rick Braa is the co-founder of AMP Services, an accounting and consulting firm specializing in helping companies grow profitability.
The Missouri Restaurant Magazine
9
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MRA Riddle ?
Name the members of the Major League Baseball Hall of Fame who spent their entire MLB playing careers with the St. Louis Cardinals or Kansas City Royals.
The first reader to provide the correct answer via email to bbonney@morestaurants.org will win a $50 gift certificate for the MRA Member Restaurant of their choice.
Congratulations to MRA member John Beverstein of The HoneyBaked Ham Co. and CafĂŠ in Columbia who provided the first correct answer to the last riddle. Question: If one-half of 24 were 8, what would one-third of 18 be? Answer: 4. Here is the algebraic solution.
1/2 (24) = 1/3 (18) 8 X 12 8
=
6 X
12X
=
48
X
=
4
Dawn Sweeney, President & CEO National Restaurant Association & NRA Educational Foundation National Restaurant Association president and chief executive officer Dawn Sweeney is widely recognized as one of the top association executives in America. Since taking the helm in late 2007, she has been instrumental in focusing the mission of the Association through a multi-year strategic plan designed to lead America’s restaurant industry into a new era of prosperity, prominence and participation. Dawn joined us in Kansas City on the night of January 30, 2016, to deliver the following keynote address at the Centennial Celebration and Inaugural Gala.
C
ongratulations on achieving this remarkable milestone! On behalf of the National Restaurant Association, thank you for leading the way. We are very proud to call Kansas City our birthplace. And it’s only fitting that we start our own “Journey to 100” here with you tonight. Over the next three years, the NRA will be celebrating significant milestones with other state restaurant associations and going coast-to-coast collecting historical artifacts from restaurant industry legends. All this will lead-up to the National Restaurant Association’s centennial which we’ll commemorate at our 2019 NRA Show in Chicago.
Dawn Sweeney, President and CEO - National Restaurant Association & NRA Educational Foundation
It’s amazing to think of how far we’ve come as an industry since 1916. If we had gathered for dinner back then, we might have been at The Savoy Grill sharing steak, spiced baked ham, boiled chicken or one of the other local favorites of the day. We could have toasted with champagne or a gin cocktail – Prohibition didn’t hit until 1920. The food and drink of 1916 wouldn’t be too remarkable to our palates – but other things have certainly changed. Think of how people are ordering now, how they’re paying, and how they’re talking about what they eat, where they eat, and all the pictures they take of all the food they eat!
100 Years of the Greater Kansas City Restaurant Association Ice Sculpture on display at the Centennial Anniversary and Inaugural Gala
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morestaurants.org | MAY 2016
When your organization was founded, credit cards were still over 30 years away. Today we’re dealing with mobile payments and mobile ordering, Apple Pay and Google Wallet. Who would have thought that cash would ever go out of style? Back in 1916, restaurant reviews were left to a few elite newspaper critics, and if you owned a restaurant, you just had to keep an eye out for them – and hope they weren’t in disguise. Of course today, every customer can be a critic or an advocate. In every corner of the internet, you can find Yelp reviews, OpenTable postings, local bloggers, tweeters, and Instagram-ers, who are talking about service, food, décor, and where they’ve been seated. 100 years ago, foods from around the world were barely starting to crop up on mainstream menus, and there were only about 40,000 restaurants in America. Today there are a million – that’s growth of over 2,000% during a time when the country’s population grew by 200%. Today diners can choose from Mexican-Thai fusion cafés, sushi bars that roll up Russian caviar, and pizza parlors offering toppings like coconut shrimp with mango chutney. Our foods are a direct reflection of the melting pot that makes this nation great. In many ways, restaurants are inextricably linked to the American dream and the American ideal. Today we are truly as diverse as America, as expansive as America, and as innovative as America. We are, in many ways, America’s industry. Your members in 1916 would be amazed today to see how far you’ve come. We have adapted and thrived as an industry throughout our history – no matter how quickly the world around us changes. Over the last hundred years, our journey has been America’s journey. And today, our story is America’s story. Restaurants reflect more than our national values; they also reflect our economy. Every economic shock is intensified by the time it hits a restaurant’s kitchen. Whether we’re talking about the cost of eggs, a shortage of limes, or the price of gasoline – restaurant owners have to deal with it all – and you do it with the slimmest of margins.
“
100 years ago, foods from around the world were barely starting to crop up on mainstream menus, and there were only about 40,000 restaurants in America.
Today there are a million restaurants – that’s growth of over 2,000% during a time when the country’s population grew by 200%. Today diners can choose from Mexican-Thai fusion cafés, sushi bars that roll up Russian caviar, and pizza parlors offering toppings like coconut shrimp with mango chutney.
”
Dawn Sweeney addresses the audience at the Centennial Anniversary and Inaugural Gala in Kansas City.
The Missouri Restaurant Magazine
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The flip side of this equation is true as well – because we don’t just feel every bump in the economy – we drive it. Today our industry is the second largest private sector employer in America, and our 2016 sales are poised to hit more than $780 billion – or four percent of the total U.S. GDP. Last year, we added 1,000 jobs a day, every day, and we anticipate our total workforce will hit 14.4 million by the close of this year.
Restaurants have taken hold of our national imagination – they’re on our TVs, our phones, and all across our lives. We can go out to eat and then come home and watch Hell’s Kitchen, Amazing Eats, Top Chef, or Chopped. This is a moment in American history when a restaurant review can go viral, the smallest startup can grow into a national brand, and a local restaurant owner can become an international celebrity.
For so many people, as it has been for decades, a job in a restaurant is still the first rung on the ladder to the American dream. Restaurants are a stepping stone to every industry imaginable. Before he founded Dell Computers, Michael Dell’s first job was washing dishes in a Chinese restaurant. Jeff Bezos of Amazon started in a McDonalds. Even Brad Pitt: long before he starred in “The Mexican,” his first job was in a Mexican restaurant.
All of this popularity is exciting – but it does put us under the microscope like never before. That’s why the work of the Missouri State Restaurant Association and the Greater Kansas City Restaurant Association is more important than ever. Because conversations are going on in Jefferson City, in Washington, and in state capitals across America that will have an enormous impact on our industry. The National Restaurant Association is committed to working with you to ensure that restaurants have a seat at the table whenever and wherever those conversations take place.
It can be critical to demonstrate to young people the opportunities we offer as an industry. The NRAEF’s ProStart program – offering two-year courses in restaurant management and culinary skills in about 1,800 high schools nationwide in all 50 states – is helping build our workforce of the future. Of course, for many people, the first job in a restaurant leads to a life-long career in our industry. Eighty percent of restaurant owners began in entry-level restaurant jobs. That’s an extraordinary measure of social mobility, and it’s a great thing for our economy. Americans love restaurants and every single day, over 130 million meals are served in a restaurant.
Tonight, of course, we’re here to celebrate and not talk politics. And celebrating 100 years of action and service on behalf of the restaurant industry is something I am thrilled to join. The celebration begins here tonight. As I said earlier, the National Restaurant Association is launching a multiyear campaign to celebrate our centennial in 2019. We are very happy to take the first step on our “Journey to 100” with all of you this evening. Thank you for the opportunity to join you and congratulations again on your past, and perhaps even more importantly, on your exciting future.
Menus, cups, glasses, advertisements and much more from the past 100 years of the Kansas City restaurant industry on display at the Centennial Anniversary and Inaugural Gala.
Centennial Anniversary and Inaugural Gala
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morestaurants.org | MAY 2016
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GREA TE R ati
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ION AT CI O
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RESTAUR AN CITY T AS S AS N A S K
irthplace ion B t a i c o l Restaurant Ass 1916-201 6
Greater Kansas City Restaurant Association Centennial Anniversary
Missouri Restaurant Association & Greater Kansas City Restaurant Association Inaugural Gala
The Celebration of the Century
The year was 1916. Three visionary restaurateurs began meeting in the basement of a Kansas City cafeteria to exchange ideas and address a common problem: the rising cost of eggs from suppliers charging unfair prices. Through their vision, the Greater Kansas City Restaurant Association was formed. In 1917, the fledgling association organized a refrain from purchasing eggs until prices returned to reasonable levels. In 1919, the group established the National Restaurant Association, which remained in Kansas City until 1927 when it moved to Chicago, and later to Washington D.C. On January 30, 2016, well over a thousand people gathered in Kansas City to honor the vision of Myron Green, George Fowler, and Guy Taylor and the Centennial Anniversary of the Greater Kansas City Restaurant Association. Oh, what a night! Mike Burris of Aeris POS Systems, recipient of MRA’s Distinguished Service Award for his dedication to the restaurant industry.
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morestaurants.org | MAY 2016
GKCRA 2016 Officers: Michael Garozzo, Vice-President; James Eddy, President; Dave Brown, Chairman.
Some of the many GKCRA Past Presidents in attendance at the Centennial Celebration and Inaugural Gala.
MRA 2016 Officers: John LaRocca, Vice-President; Buddy Lahl, President; Herman Styles, SecretaryTreasurer; Bob Luke, Chairman
MRA Hall of Fame inductees, Todd Hulse and Vic Allred reflect on their careers in the restaurant industry. Both men began working in a restaurant as teenagers: Hulse in Kanoplis, Kansas; Allred in Versailles, Kentucky. Neither ever saw any reason to leave.
Anthony Fink, Kansas State University. The first recipient of the Ronald L. Barkley Memorial Scholarship
The Missouri Restaurant Magazine
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GREA TE R
N
ati
100
YEARS ona
ION AT CI O
Greater Kansas City Restaurant Association Centennial Anniversary
RESTAUR AN CITY T AS S AS N A S K
Missouri Restaurant Association & Greater Kansas City Restaurant Association Inaugural Gala
irthplace ion B l Restaurant Associat 1916-201 6
Special Thanks to our sponsors Diamond
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Visit us online at www.GKCRA.com.
Restaurants Give Back The Brass Rail – Scott Ellinger For many, Thanksgiving is the best day of the year. It is a day to celebrate with family and friends over a bountiful meal and offer thanks for the blessings in our lives. What becomes of the day, though, when the meal is less than bountiful? Scott Ellinger, owner of The Brass Rail in O’Fallon decided fewer families would answer that question on Thanksgiving Day 2015. After receiving a letter seeking Thanksgiving donations for needy families, Ellinger vowed he would find a way to feed a thousand people. With help, he did. The manner in which a decision by one man with a generous spirit resulted in the provision of a traditional Thanksgiving meal to over 1,300 people is remarkable. Ellinger decided he would accomplish the undertaking with volunteers. He reached out to local churches and posted a call for help on Facebook. After the list of volunteers reached 200 people, many others willing to pitch-in had to be turned away. At every turn, the response of the community was overwhelming. In the days leading up to the holiday, a woman called from a grocery store to say, “I want my children to learn a lesson in giving. What do you need?” A short while later, two youngsters arrived toting bags of groceries. Others walked in the restaurant with donations and simply handed them to the hostess. A company provided a refrigerated truck to store the food that would be needed. Two culinary schools loaned cooking equipment. Two executive chefs worked on the cook’s line with Ellinger for eleven consecutive hours. A restaurant from miles away arrived with a whole hog and carved it onsite to feed the army of volunteers.
“
If you can’t feed a hundred people, ~ Mother Teresa then just feed one.
”
Scott Ellinger - The Brass Rail
The deliveries began at 10:30 a.m. as drivers left with meals consisting of turkey, ham, mashed potatoes, scratch made cranberry sauce, green beans, dressing, yams, whole pies and more. Some families sent back a word of thanks with pictures of their Thanksgiving table after they had transferred the food to their personal serving dishes. Deliveries were made to homes more than an hour’s drive away, including 25 meals delivered to a tent village. One woman called to ask if it was possible to receive a delivery of uncooked food on Wednesday, explaining her parents were coming over for the holiday and she did not want them to know she couldn’t afford to feed them. Although she lived 45 minutes away, the delivery was made. A restaurant should, Ellinger tells his people, find a way to say, “Yes.” Carry-out meals were provided to those who drove to the restaurant. Two separate lanes were required to allow for an efficient flow of traffic. The Brass Rail was open for folks desiring to enjoy Thanksgiving in the fellowship of others. The meals were brought to their table. Some diners left a tip, perhaps a dime or quarter at a time, to express their appreciation. The tips, when added to other cash donations, equaled nearly $3,000. The best use for that money would be, Ellinger decided, coats, hats, and gloves to help children through the winter. Thanksgiving 2015 will be remembered by many as a day on which they gave thanks for a couple hundred volunteers, The Brass Rail, and Scott Ellinger. On occasion, we are reminded of the generous spirit of the American people. And for that, we can all be thankful. The Missouri Restaurant Magazine
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Brace Yourself! What to Expect With the Proposed New Federal Wage and Overtime Rules Changes in the minimum salary level required to meet the ‘White Collar’ exemptions of the Fair Labor Standards Act overtime rules has some potentially serious ramifications for the restaurant industry, particularly in employees in a supervisory capacity. You need to be ready now to ride out what experts expect to be massive wage increases.
By Bryan Jacoutot
The Missouri Restaurant Magazine
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Preface: Employers, and their attorneys, are bracing for significant changes to “white collar” exemptions in the Fair Labor Standards Act (FSLA) addressed in this article. Through the first part of this year, legal and policy wonks had guessed that the final ruling would not be published until Labor Day. It’s coming faster than most observers expected. In mid-March, the Department of Labor (DOL) sent its final rule revising white collar overtime exemption regulations to the White House Office of Management and Budget. Given the average review period of such rulings, experts believe the final ruling could be published as early as late spring. As might be expected, the business community and their advocates pushed back at the regulation changes during the 60-day period of public comment. Whether their concerns will be given consideration in the final ruling is to be seen; however, the legal experts I’ve spoken with seem pretty sure of at least one thing. They predict it will raise the minimum salary level for the administrative, executive and professional exemptions to the 40th percentile of weekly earnings for full-time employees — $970 per week or $50,440 per year. This is a big deal. And it is imperative that restaurant owners not only understand these changes, but work with their legal, financial and human resources adviser to determine how they might affect their businesses and take measures to manage labor costs in their wake. In this article, Bryan Jacoutot, a lawyer with law firm Taylor English Duma LLP, provides details of the law and some strategies to help guide these decisions. If there is any good news for employers, Jacoutot observes that, typically, the DOL offers a compliance period of at least a few months but it’s possible that the period will be extended for a couple of reasons. First, the extreme wage increase cautions against mandating compliance too quickly, before employers have really had the time to formulate an effective strategy going forward. Second, with 2016 being an election year, it is unlikely that the administration would want to expose a potential rift in the voting class in case things don’t go as smoothly as it is hoped they will.
IN JULY OF LAST YEAR, the Wage and Hour Division of the Department of Labor posted a Notice of Proposed Rulemaking to the public. Among other things, the proposed rule signals a drastic increase in the minimum salary requirement needed to exempt certain employees from being paid overtime wages after they’ve worked 40 hours in a given week. The rule also promises to install an indexing mechanism that will annually update the minimum salary based on the salary levels in the United States for a given year. Before delving into the proposed rule, a brief background on the current state of the FLSA overtime requirements will help explain the new rule.
A Little History As you likely know, the Fair Labor Standards Act guarantees overtime pay at a rate of not less than one and one-half times the employee’s regular rate for hours worked over 40 in a workweek. One of the more common exceptions to this general rule is the exemption of executive, administrative and professional employees (otherwise known as the “EAP” or “white collar” exemption). For an employee to be subject to the EAP exemption, and thus, ineligible for overtime pay, they generally must pass each of the following three tests with respect to their employment: The ‘salary basis’ test. The employee must be paid a predetermined and fixed salary that is not subject to reduction because of variation in the quality or quantity of work performed. The ‘salary level’ test. The amount of salary paid must meet a minimum specified amount.
Nevertheless, even if the DOL takes the “slow” approach to compliance, employers can still expect a compliance date of sometime toward the end of 2016, or early 2017. That will be here before we know it, goes the old saw.
The ‘duties test.’ The employee’s job duties must primarily involve executive, administrative or professional duties as those terms are defined by the regulations proffered by the DOL from time to time.
In short, writes Jacoutot, “Employers should start directly addressing compliance issues — now.” Jacoutot also notes that this article is for general information, and not a substitute for qualified legal counsel addressing the specific circumstances of your business. We hope, however, that it helps you have a more effective conversation with your advisers, and greater awareness of how these regulatory changes might affect your business.
Each of the three factors must be met in order to qualify for the EAP exemption. A common misconception is that if an employer simply pays their employees a salary above the federally mandated minimum, then they are exempt from having to pay overtime. (See “A Review of the ‘White Collar’ Exemptions under the 2004 Regulations” on Page 28.)
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The DOL last made an update to the salary level test mentioned in Factor 2 in 2004. Following that update, the minimum salary permitted wherein an employee could be EAP exempt was $455 per week, which annualizes to $23,660 per year for a full-year worker. The DOL did not expressly propose any changes to the duties test in the July 2015 proposed rulemaking. It is clear, though, that they do desire to make changes. The DOL will likely tread carefully regarding the duties for fear that doubling the minimum salary requirement and substantially changing the duties test would create too significant a backlash. Again, without knowing the details of the final ruling, particularly after the comment period, it is not certain how the DOL will change the duties tests. As of now, the primary inquiry respecting an employee’s ability to take advantage of the EAP exemption continues to revolve around whether their “primary duty” fits into the “executive,” “administrative” or “professional” categories. What seems more certain is that the proposed rule contemplates an ambitious increase in the mandated minimum salary level. And that promises to be very costly to employers.
The Proposed Rule Since 2004, the minimum salary level has remained unaltered. Last year’s proposed rule from the DOL hopes to change that. The DOL is also proposing to add an indexing component to the rule that would formulaically adjust the minimum salary level on an annual basis. Although the DOL notice is only technically a “proposed rule,” it seems unlikely that the numerous comments the public responded with will sway the department from its plan of using the 40th percentile of earnings from “full-time salaried workers.” In 2013, the statistical year the department used in its proposed rule, this level was $921 per week with an annual salary of $47,892. In the years since then, the weekly salary minimum has jumped to an estimated $970 per week ($50,440 per year). The massive increase in the salary level minimum coupled with the indexing requirement has some potentially serious ramifications for the restaurant industry, particularly with employees in a supervisory capacity. As noted, the “duties test” targets employees for exemption who work in an executive, administrative or professional capacity. The executive employee is classified, in pertinent part, as one “whose primary duty is management of … a recognized department or subdivision thereof; who customarily and regularly directs the work of two or more other employees…” and who has the authority to actually hire/fire employees or whose opinions on the hiring/firing of employees are given particular weight. This, in a nutshell, describes many shift managers at full-service restaurants. Such employees are often also paid on a salary, rather than hourly basis. As a result, they likely currently qualify for the EAP exemption from overtime unless they make less than $455 per week. (That said, plaintiffs’ attorneys often challenge whether those managers are exempt, based on the duties test. In 2001, Treetop Enterprises Inc., the second-largest franchisee of Waffle House, a popular restaurant in the Southeast, was ordered by a federal judge to pay about $2.9 million in overtime pay owed to its managers. The court rejected Treetop’s claims that the managers The Missouri Restaurant Magazine
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were “executives” who were exempt from FLSA overtime requirements, because the Waffle House managers performed nonmanagerial tasks as their primary jobs, with management roles being secondary. It didn’t help that the company’s training manual defined their managerial duties as subordinate to cooking.) Nonetheless, the proposed new rule could present another problem for restaurant employers who employ shift managers — and other similarly situated employees — at a salary level between $455 per week and $970 per week. In years past, these employees would have been safely above the salary minimum, but the new rule may engulf a sizeable amount of them, requiring employers to change their compensation structure — or begin paying them overtime for hours worked in excess of 40 per week. The proposed rule also considers the inclusion of nondiscretionary bonuses to the pool of compensation that counts toward meeting the minimum level; however, before employers consider adding an aggressive incentive bonus structure for their employees, they should note that the DOL
The Federal Fair Labor Standards Act Is a Floor, Not a Ceiling Changes in the minimum salary level required to meet the ‘White Collar’ exemptions of the Fair Labor Standards Act overtime rules has some potentially serious ramifications for the restaurant industry, particularly in employees in a supervisory capacity. You need to be ready now to ride out what experts expect to be massive wage increases.
has signaled its intent to cap bonuses at 10 percent of the standard weekly salary level for the purposes of compliance. In other words, if the minimum salary level is $970 per week, then the employer can only use nondiscretionary bonuses to satisfy $97 of that. Although the DOL received some fairly persuasive comments arguing against any sort of cap, it seems unlikely they will change their tune for the final rule. With such a drastic change on the horizon for millions of employees and their employers, it is prudent for business owners to start planning now. While the task may seem overwhelming, there are a number of things that can be done to minimize exposure.
Examples of Options for Compliance There are a number of routes an employer can take to effectuate compliance with the proposed rule. The following are intended to serve as examples. Given the complexity of this rule, it is important for businesses attempting to comply to seek the advice of legal counsel, as each factual scenario presents different pros and cons. If an employer has a previously exempt employee with an annual salary of $42,000, the employer has a couple of options from which to draw.
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First, the employer can simply give the employee a raise of $8,400, safely removing the employee from overtime eligibility for purposes of the salary-basis test. The pros of this are apparent. If the employee also meets the duties test, the employer need not track the hours worked by the employee, and business can remain apace. The cons, unfortunately, are also fairly obvious. Here, the employer eats the entire cost of rule compliance with a direct and substantial burden to its coffers. At its core, this “raise” represents a 20 percent increase in the employee’s salary without the addition of any new responsibilities or necessary skillsets. While this will undoubtedly increase employee morale (at least with similarly situated employees), this may not be a viable option for business owners without much cash to spare, or for those that have a significant amount of employees in this situation. Moreover, other employees who either are already subject to the overtime rule, or who maintain a salary well above the new minimum may be agitated by what appears to be a meritless raise for the lucky few. And they might also demand similar raises. Second, the employer may choose to restrict the employee’s weekly hours to 40. While this option ensures the employer doesn’t take on any costs with respect to the employee, it carries with it its own challenges. The employer may, for instance, need to hire new employees to make up for the work not being done due to the fact that an employee, who normally
Wait, Our Little Restaurant Doesn’t Gross $500,000 In Sales… Foodservice businesses with annual gross sales from one or more establishments that total at least $500,000 are subject to the Fair Labor Standards Act (FLSA). What if your small operation doesn’t meet this threshold? The U.S. Wage & Hour Division of the Department of Labor says, “any person who works on or otherwise handles goods that are moving in interstate commerce is individually subject to the minimum wage and overtime protection of the FLSA. For example, a waitress or cashier who handles a credit card transaction would likely be subject to the Act.”
worked 50 or 55 hours per week, now can only work 40 hours per week. Further, simply adding a new employee and telling that person to “pick up where Employee X left off” is not a practical solution for many positions, especially supervisory ones. If the responsibilities of a given job do not readily change hands from employee to employee, this may not be a viable route. Another option would be to have the employer opt to simply pay the 1.5 times overtime pay for hours worked in excess of 40 per week. If, for example, our $42,000/year sample employee typically works 50 hours per week, that would mean the employer would have to pay an additional $15,750 per year to maintain compliance with the rule. Of just about any course of action, this would seem to be the least practical. It nearly doubles the amount needed to simply raise the employee’s salary to the threshold level. With the new annual indexing requirement, however, it does cut down on time spent on compliance. An employer who raises the salary, as in Example 1, for instance, will need to check every year to ensure compliance with the annually adjusted 40th percentile salary. The aforementioned examples seem to be the most readily apparent. But there are other avenues an employer can pursue to lessen the direct financial burden of compliance. An employer can, for instance, pay the employee at a modified pay rate. If an employer is aware that their salaried employees typically work an average of 50 hours per week, for instance, they can “modify” the pay rate to allow for a lower salary, or simply convert them to hourly employees. For a hypothetical employee making a $40,000 annual salary, their weekly pay rate of $769.23 would need to be reduced to $559.60 per week. Modifying an employee’s salary downward is not something any employee wants to see, especially when their conduct or production doesn’t warrant it. Therefore, the employer should go to great lengths to explain why the change is happening, and how it will affect (or, more accurately, not affect) their “real” compensation level. All that said, it may still be a tough pill for an employee to see such a precipitous drop in their annual salary, even if they know the reasons. As an alternative, the employer may elect to convert certain salaried employees to hourly. In electing either of these two methods, an employer needs to keep in mind 1) the effect the shift could have on employee morale; and 2) the very real problem that a reduction in workload will directly contribute to the employee earning less. For those who have been on salary for a long time, however, this “new normal” could present its own challenges.
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A fifth option for compliance with the overtime regulations is paying a fixed salary for a period greater than 40 hours per week. For simplicity’s sake, let’s say an employee is paid $1,000 per week with the understanding that the salary is intended to cover 50 hours. That works out to an hourly rate of $20. This employee would still be entitled to an overtime premium for hours worked in excess of 40, but the straight time hours would already be covered by the salary for the 10 hours beyond 40. Therefore, the premium would only be 0.5 times the regular rate, or an additional $10/hour for the 10 hours worked in excess of 40, bringing the employee’s overall weekly compensation to $1,100. To use this method, the employer must be sure to communicate, in writing, the intended amount of hours the salary is to compensate for. It’s also worth noting that the 1.5 times compensation rate comes back into play for hours worked over 50 hours. It’s altogether possible that after perusing each of the aforementioned potential compliance paths, an employer reading this article is going to be less than satisfied with their options. Unfortunately, with the onset of new regulations like those now being proposed by the DOL, complete costavoidance is not always possible.
By their design, these regulations are intended to dramatically increase the wages of as many as 6 million American employees by transferring the wealth from employer to employee. Whatever the wisdom of this course of action, employers should also take note of the intended timeline of the rollout of the regulations for 2016.
How to Prepare Unfortunately, an employer simply picking one of the aforementioned compliance paths does not automatically render them compliant. Indeed, as noted earlier, the DOL has signaled that many employers may be misclassifying employees as exempt purely on the basis of their salary, when that actually only satisfies part of the white collar exemption. As a result, the time leading up to the implementation of this rule offers a great opportunity for employers to conduct a self-audit to review the exempt and nonexempt status of each one of their employees. In that vein, employers should also seek to educate senior management about the new regulations, and the company’s intended response to them. The self-audit addressed earlier will provide employers with valuable information about their workforce and how each of their employees are classified under the rules.
You need to be ready now to ride out what experts expect to be massive wage increases.
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While that is great in the near term, the long-term outlook for compliance will likely be a tough road and the various levels of management within the organization need to be prepared to adapt to changing regulations, especially in light of the new annual indexing requirement. No longer will employers be given the opportunity to comment on proposed changes to the salary minimum requirement. Nor will they have the advantage of a compliance period to adapt. Instead, the formulaic annual updating will require a system in place in the organization to review and, if necessary, adjust each employee’s compensation levels every year to ensure compliance. Management also needs to be aware of the lesser-known reality that changing an employee’s day-to-day duties can affect their exemption as well. As noted earlier, many employers and managers erroneously believe that merely paying an employee a salary above the “salary minimum” safely renders them exempt from the FLSA overtime compliance rules. As this article has attempted to illustrate, that is not the case.
Not only is now a good time to examine your employee’s duties for compliance with the current “duties test” through a self-audit, they should be looked at with an eye toward the fact the DOL is seeking a change in that layer of the white collar exemption as well.
Only Scratching the Surface While this article addressed the proposed changes to the overtime regulation in a relatively robust manner, it really only scratches the surface of compliance. As noted, each scenario offers its own compliance quirks, and it is important that employers secure competent counsel when embarking on any course of action. If you are concerned that your organization may have wage-and-hour issues or may have classified some positions improperly, an attorney can provide details about your rights and responsibilities — hopefully before you are faced with the unfortunate onset of a lawsuit. RS&G For a Review of the “White Collar” Exemptions Under the 2004 Regulations see page 28.
Satisfying each layer of the three-part white collar exemption test is necessary. This article has already addressed at length the need for compliance with the salary level test. One thing it has not addressed is compliance with the “duties test.”
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A Review of the ‘White Collar’ Exemptions Under the 2004 Regulations There is still a question if the final ruling will change the 2004 exemptions for “white collar” employees, who are typically not eligible for overtime pay. The proposal addresses the “standard duties” tests and requests comments on the current exemptions for white collar employees, which include executive, administrative, professional and outside sales employees, and certain computer employees. But it’s not that simple. When the law was changed in 2004, it made clear that overtime law is based on occupations, salaries and duties. Job titles are irrelevant. Here is a rundown of the white collar exemptions, based on the 2004 changes to the law. Please note, we provide them simply as a reference and reminder of how the Fair Labor Standards Act (FLSA) addresses these exemptions under the current law. They are subject to modification under the proposed new law.
Executives There are two governing factors for the overtime exemption for “executives.” First, the employee must engage in specific duties as part of his or her primary job. And, second, he or she must be paid on a salaried basis of at least $455 per week, not including bonuses. Any employee who does not earn this much, will not qualify for executive exemptions. What does it mean to be paid on a salary basis? To be considered a salaried employee, the employee has to receive a predetermined amount of salary each week, regardless of quality or quantity of work performed. One of the traps for unwary employers is that they can change the employee’s exempt status by docking pay, in certain cases. If you furlough an employee for less than a week, you cannot make deductions from his salary and still maintain his exempt status, with some exceptions. For example, you can make prorated deductions for absences of a full day for personal reasons, such as an illness. You cannot dock pay or suspend exempt employees without pay for minor workplace rules infractions, such as not securing the back door. However, workplace deductions or nonpaid suspensions based on violations of written conduct rules — such as sexual harassment or workplace violence, are acceptable, without losing the exemption. In addition to minimum salary requirements, under the 2004 changes to the FLSA, to be exempt from overtime laws as an executive, the employee’s primary duty has to be management of an enterprise or recognized subdivision. The general manager would clearly be exempt under this definition of duties. Management of a recognized subdivision might include managing the kitchen, managing the shift or front-of-the-house operations. But you need to be careful that the position requires bona fide management. An assistant general manager may or may not be an exempt employee. For example, the manager can’t just float around. He has to be responsible for a recognized division, not just a group of tables. 28
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Another requirement is that these managers also customarily and regularly direct the work of two or more fulltime employees or their equivalent. The equivalent of two fulltime employees would be four part-time employees. Also, if there are two managers to a group, there would have to be at least four full-time employees or their equivalents, in their charge. In 2004 the law added a new twist to the executive exemption in that the exempt executive must either have the authority to hire or fire employees, or their recommendations are given particular weight. Experts advised that this authority or influence should be clearly described in the employee’s job description. Under the 2004 law, if the employee is also a business owner with at least 20 percent ownership of the business and is involved in management, he is exempt without having to meet the salary requirements.
Administrative personnel “Administrative” employees may also be exempt under the regulation as it stands before the proposed new changes. First, they have to meet the same salary requirements (at least $455 per week, at least until this is changed by new regulations). Regarding their duties, they must be engaged in office, non-manual labor (which includes most restaurant work) that is directly related to the management or general business operations of the employer. Also their primary duties should involve the exercise of discretion and independent judgment in matters of significance. For example, this would include someone who independently maintains inventory levels or hires contractors. As an example, if the employee’s duty is to order the wines specified by a manager, that employee would not be considered exercising discretion or independent judgment over matters of importance. But if the employee’s duties
include ordering wines with the responsibility to determine which wines to order, that would be considered the exercise of independent judgment. The administrative exception usually pertains to multiunit operations, with specialized job functions such as trainers.
Professionals As of 2004, the rules also exempt so-called “learned professionals” and “creative professions” from the overtime laws. A learned professional’s primary duty has to involve an advanced degree of knowledge, predominantly intellectual, with extensive exercise of discretion and judgment. Typically, they must be in a field of science or learning, and have obtained their professional status through a prolonged course of study. These include lawyers, doctors, engineers and CPAs. How does this relate to the hospitality industry? As of the 2004 regulations, the DOL recognized that a four-year college degree in the culinary arts meets this standard. Executive chefs who manage a kitchen already qualify under the executive exemption. Under the new laws, an employee with a four-year culinary arts degree would be exempt from overtime pay as a learned professional, as long as they were applying their training as a primary duty, such as menu planning. The restaurant industry has the National Restaurant Association to thank for this exemption, which resulted largely from its comments. Of course, a lot of chefs don’t possess a culinary arts degree. In this case, they might fall under the “creative professional” exemption. To qualify, they must earn at least $455 per week under the current law, of course. Their primary duties must require invention, creation, originality and talent in a recognized field of artistic or creative endeavor.
Line cooks are not included; typically, all they do is follow strict guidelines set forth by the chef or kitchen manager.
Other exempt employees The new regulations provide exemptions for computer programmers and analysts, as well as highly compensated employees (those who make at least $455 per week in salary under the 2004 regulations, but have a total compensation of $100,000 a year). These positions are few and far between in the restaurant business. A more common class of exempt employees in the restaurant business under the 2004 regulations is the sales representative, such as the guy or gal who promotes catering or banquet operations. There is an exemption for outside sales representatives, defined as those who make sales and obtain orders and contracts away from the office. Most catering sales representatives are nonexempt, since they are sitting in a corporate office, running an advertising campaign and taking orders on the telephone. Again, the aforementioned information is based on the current regulations, as of 2004. As you can see, the increase from $455 to $970 a week as the threshold salary can touch a lot of positions. It remains to be seen if there will be changes to the white collar exemption; however, as noted in the main article, experts fully expect the weekly salary threshold to increase to $970. Additional Sources: The U.S. Department of Labor provides additional information on the Fair Labor Standards Act and the new overtime regulations at http://www.dol. gov/-featured/overtime. This article reprinted, with permission, from Restaurant Startup & Growth Magazine. Want to read more articles like this? Send an email to bbonney@morestaurants.org to receive a free 12-month trial subscription courtesy of RSG Magazine.
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