Golf Course Advisory Board Agenda and Packet 2015 04 20

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Citvof Louisville PARKS & RECREATION Memorandum To: Golf Course Advisory Board From: Joe Stevens Date: April 20, 2015 Re: Golf Course Volunteers I have received several inquiries about utilizing volunteers at Coal Creek, and rather than pay wages, compensate "volunteers" with free golf. Unfortunately, if the City implements this type of program it will be a violation of the Department of Labor's (DOL) rules regarding paying wages for hours worked. Accompanying this memorandum, please find an article about several Florida golf courses that compensated starters and rangers with free golf for their work at a golf course with the result being that employees must be compensated for real work even if they would rather be compensated with free golf. The Human Resources Director recommended that I use the information from these law suits to protect the City from being in a situation where we have to pay back wages and penalties for not complying with DOL's wage and hour laws even though it appears to be a practice that has and is being used, and in some instances, advertised at other golf courses. Typically, back wages are based on a 3 -year look back of hours volunteers /worked and then there are penalties assessed on top of those wages depending on circumstances such as: • Did the Golf Course know about the rules regarding volunteers and wage and hours laws and they chose to ignore it? • Did they cooperate with the investigation? • Did they meet the deadlines for providing information and was it complete? o The DOL requests for information are typically required within 30 days of receipt of notice. This can be difficult depending on accuracy of records or lack thereof and that too can factor into the penalties. The City has an obligation to abide by standards set forth by DOL even if inconsistent with the way some of our neighboring golf communities "barter for services." cc: Malcolm Fleming Kathleen Hix David Baril 14