This review of the Department of Labor’s recently-announced Payroll Audit Independent Determination (“PAID”) program comes with side of skepticism. With all new voluntary programs, trust but verify.
PAID was rolled out in March 2018 with much fanfare about its benefits. PAID is a 6-month pilot program sponsored by the DOL’s Wage and Hour Division (WHD) whereby an employer can voluntarily engage in a self-audit of its payroll practices. If that audit reveals suspected or actual violations of overtime or minimum wage provisions of federal law, the employer discloses those to the WHD. Specifically, the employer must identify the violations, the affected employees, the timeframe, and a calculation of back wages owed to each affected employee. The WHD then begins a process with the employer to identify and remedy violations. The process will likely include the WHD asking for information which must then be provided. Continue reading