UUA Office of Church Staff Finances
Guided by Unitarian Universalist values,
we equip congregations for excellence as employers
and their staff for financial competence and well-being.
Compensation and Staffing News
July 2024

Editor's Note

Dear Readers,

We've been fielding many questions about the new exempt salary threshold. We address a few of them below. And check out our new flow chart!

Faithfully,
Jan Gartner, Compensation and Staffing Practices Manager
Read Back Issues of This Newsletter

New Leaders or Employees?

Keep Us Informed! 
Lay leader positions often turn over in the summer, and it's a common time for staff changes, too. Please keep your leader and staff listing up to date in My UUA. The information in My UUA feeds into our database, allowing us to send communications by role. Additionally, key positions are listed in the UUA Directory.

It's also important to submit employee changes directly to our office for benefits purposes. This includes salary and hours changes, new home addresses, terminations, and retirements. 

Here are the links you may need:

Helping Staff Pay for "Other" Health Insurance

We're On a Learning Curve
Congregational staff often get their health insurance from a source other than their employer. They are sometimes covered through a spouse or another job. Or they might have marketplace coverage or Medicare. 

Some employers want to reimburse employees for a portion of the cost of that other insurance, but Affordable Care Act law changed what's allowable. In the early days of the ACA, our team researched the rules, got clarifications from legal counsel, and created guidance for congregations. Now, nearly a decade later, we're finding that the info we've been sharing cannot be easily verified, so we're having our guidance reviewed by an employee benefits attorney. Thank you for your patience as we learn more about this very complex area.

Switching Insurance Payments to ACH

For Streamlining and Enhanced Security
Many congregations have already begun paying their insurance invoices through the ACH option introduced last year. To help us further streamline our processes, we're asking all employers participating in UUA Insurance Plans to shift to ACH payments by September 30. If you are not yet paying your invoices directly through this automatic debit method, you should be receiving a copy of the ACH authorization form with your monthly invoices. You'll also find it at the button below.

ACH payments allow for faster processing, reduced administrative costs, and enhanced security. Thank you for making this change by September 30!
Authorize Direct Payments

Exempt Salary Threshold Increase

We're fielding lots of questions about the recent Fair Labor Standards Act exempt salary threshold increase. The responses below complement the information found in our resources.

Are churches treated differently under the FLSA?
Employees may be covered by the Fair Labor Standards Act through enterprise coverage or individual coverage. Enterprise coverage applies to businesses with commercial activities that generate at least $500,000/year. Few congregations would meet this definition. However, individual coverage is based on a very broad definition of interstate commerce and communications. In addition, some states have laws parallel the federal FLSA that may broaden the coverage. It is wise to assume that your staff are individually covered. The "ministerial exception" is discussed below. See our FLSA FAQ for more.

Is the recordkeeping requirement new?
No. Employers have always been required to keep records of daily and weekly hours worked by nonexempt staff. This is how you prove that you've been paying: 1) at least the federal minimum wage (or state or local minimum, if higher) for actual hours worked each workweek, and 2) the overtime rate (time-and-a-half) for any hours over 40 in a workweek or based on state law, if stricter.

Can you explain salaried nonexempt status? 
Many people assume that nonexempt means hourly. It is legal to pay nonexempt staff a salary (or some other way, like per event), but it's tricky. Because they are nonexempt, you still have to follow the Fair Labor Standards Act (FLSA) rules. In other words, keep records of daily and weekly hours worked. Again, this is to show that you've paid the employee at least the minimum wage per hour worked as well as overtime pay as applicable. See our Classifying Your Workers slide set.

Which staff members fall under the ministerial exception?
The ministerial exception exists outside of the FLSA and there is less detailed information about it. We are not lawyers and we can't make individual determinations, but we've included some pointers and guiding questions in our materials. This exemption is used for nearly all ministers and sometimes for other staff deemed to have "essential religious duties." We urge careful use of this exemption since it effectively denies employees the protections of the FLSA and certain other labor laws. See the FLSA FAQ.
Can you make us a flow chart?
Actually, this isn't a question we got from you, but something we thought would be helpful. It's with the other resources on our Worker Classification page (at the button below). Here are links to the individual resources:
  1. START HERE! Classifying Your Workers: the basics of the FLSA.
  2. FLSA FAQ: details of the law. Look here for exemption criteria and recordkeeping requirements.
  3. NEW! Exempt or Nonexempt Flow Chart
  4. FLSA Compliance Guide takes you through the process of checking for legal compliance, with options for changing pay or classification if needed.

Review Worker Classification Info and Resources
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The UUA Office of Church Staff Finances provides general information to
help equip and empower congregational leaders in their decision-making.
We are not legal or tax professionals and we do not track state law. Congregations are solely responsible for their legal obligations. We encourage you to consult your own legal and tax advisors for specific guidance.

UUA Compensation and Staffing

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