Evaluation of the Wage and Hour Division Enterprise-Wide Enforcement Pilot
Challenge: The U.S. Department of Labor (DOL) Wage and Hour Division (WHD) is looking to improve enforcement outcomes in terms of ensuring workers’ rights are being protected per the Fair Labor Standards Act, which governs such issues as overtime pay and other worker treatment protections. DOL’s goal is to test the effectiveness of a pilot DOL WHD initiative in one particular industry in order to see if this initiative has a measurable impact on Fair Labor Standards Act violation rates.
Solution: The Summit team is implementing a formal test of the enforcement strategy applied to employers and related firms based on a quasi-experimental design. Summit started by developing a sampling frame from industry databases and drawing a representative sample of establishments to determine a baseline level of compliance in the industry and differences in compliance across types of establishments, employers, and related benefiting firms. The design of the study involves selecting a group of enterprises to receive a “treatment,” in this case a new and more comprehensive enterprise-wide intervention strategy, and then sampling other industry establishments in a treatment control setting to analyze the effectiveness of the treatment. In addition, Summit is evaluating the process of applying the enforcement initiative to different types of employers and related benefiting firms. As part of the analysis, we are reviewing industry features that will inform the design of the initiative, including an industry analysis, and a process evaluation of the DOL initiative’s implementation.