Agenda 11/14/2023 Item #16E 5 (12 Settlement Agreemeent and Releases)11/14/2023
EXECUTIVE SUMMARY
Recommendation to approve and authorize the Chairman to sign twelve (12) Settlement Agreements and
Releases by and between Collier County and employees in the EMS Battalion Chief II position classification,
allowing for reimbursement of actual wages earned but not paid to certain employees from July 3, 2021, to
June 30, 2023, as a result of the County’s good faith misclassification of status under the Fair Labor
Standards Act (FLSA).
OBJECTIVE: To approve payment of back wages for the period between July 3, 2021, and June 30, 2023, and
authorize the execution of Settlement Agreements and Releases for employees in the EMS Battalion Chief II
position who were entitled to overtime wages but were not paid as a result of the County’s good fai th
misclassification of their employment status as exempt under the FLSA.
CONSIDERATIONS: FLSA and its regulations provide, in part, standards for certain job classifications to be
exempt from overtime compensation. In December 2022, the County’s Human Resources Division received a
notice letter from the United States Department of Labor, Wage and Hour Division (WHD) indicating their intent to
investigate Collier County for compliance with the Fair Labor Standards Act (FLSA). Specifically, they would be
evaluating FLSA compliance for twelve (12) employees in the position of EMS Battalion Chief II. Following the
WHD Investigator’s review of records submitted by the County and in-person interviews with over half of the EMS
Battalion Chiefs, the County was informed of the Department of Labor’s determination that these employees should
be classified as non-exempt and eligible for overtime compensation pursuant to FLSA regulations.
The County reclassified the EMS Battalion Chief II position title in the County’s EMS Pay and Classification Plan
as non-exempt, effective July 1, 2023, following a final recommendation from the Department of Labor.
Additionally, the County will provide compensation to the employees assigned to this position title for actual
overtime worked and earned from July 3, 2021, to June 30, 2023. To the extent that any reclassified employee
received compensatory time in lieu of wages during that period, that employee will be compensated at the
appropriate non-exempt employee overtime rate to make up for any shortfall in payment of wages.
The Department of Labor WHD Investigator found that the EMS Battalion Chief II position did not meet the FLSA
duties test for an administrative exemption, although the County believed the employees were properly classified as
exempt. To qualify for the administrative employee exemption, all the following tests must be met:
• The employee’s primary duty must be the performance of office or non-manual work directly related to the
management or general business operations of the employer or the employer’s customers; and
• The employee’s primary duty includes the exercise of discretion and independent judgment with respect to
matters of significance.
Attached, as Exhibit 1, is a sample copy of the Settlement Agreement and Release prepared for execution between
the County and the EMS Battalion Chief II employees entitled to reimbursement under the FLSA.
FISCAL IMPACT: The fiscal impact resulting from the proposed Settlement Agreements, which the County is
required to make pursuant to Federal law, is estimated at a cost not to exceed $513,000. Funding for the settlement
payments is available within EMS Fund (4050).
GROWTH MANAGEMENT IMPACT: There is no growth management impact associated with this action.
LEGAL CONSIDERATIONS: The FLSA requires the County to provide overtime compensation to the
employees who were previously classified as exempt for a two-year period prior to the reclassification. The current,
active employees at issue have been properly reclassified. The Settlement Agreement and Release has been
prepared and reviewed by this Office. This item has been approved as to form and legality and requires majority
vote for approval. - CMG
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11/14/2023
RECOMMENDATION: That the Board approve and authorize the Chairman to sign Settlement Agreements and
Releases by and between Collier County and employees in the EMS Battalion Chief II classification, allowing for
reimbursement of actual overtime wages earned but not paid to affected employees from July 3, 2021, to June 30,
2023.
Prepared by: Amy Lyberg, Division Director - Human Resources
Attachments: Exhibit 1, Sample copy of Settlement Agreement and Release
ATTACHMENT(S)
1. EXHIBIT 1 - Settlement Agreement and Release EMS Battalion Chiefs (DOCX)
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11/14/2023
COLLIER COUNTY
Board of County Commissioners
Item Number: 16.E.5
Doc ID: 27121
Item Summary: Recommendation to approve and authorize the Chairman to sign twelve (12) Settlement
Agreements and Releases by and between Collier County and employees in the EMS Battalion Chief II position
classification, allowing for reimbursement of actual wages earned but not paid to certain employees from July 3,
2021, to June 30, 2023, as a result of the County’s good faith misclassification of status under the Fair Labor
Standards Act (FLSA).
Meeting Date: 11/14/2023
Prepared by:
Title: Division Director - Human Resources – Human Resources
Name: Amy Lyberg
10/30/2023 2:17 PM
Submitted by:
Title: Division Director - Human Resources – Human Resources
Name: Amy Lyberg
10/30/2023 2:17 PM
Approved By:
Review:
Human Resources Amy Lyberg Director Review Completed 10/30/2023 2:17 PM
Corporate Business Operations Kenneth Kovensky Corporate Business Operations Review Completed 10/30/2023 9:31 PM
County Attorney's Office Colleen Greene Level 2 Attorney Review Completed 11/01/2023 7:10 PM
Emergency Management Michael Choate Additional Reviewer Completed 11/03/2023 12:24 PM
Capital Project Planning, Impact Fees, and Program Management Ian Barnwell Additional Reviewer Completed
11/07/2023 3:47 PM
Office of Management and Budget Debra Windsor Level 3 OMB Gatekeeper Review Completed 11/07/2023 3:51 PM
Office of Management and Budget Christopher Johnson Additional Reviewer Completed 11/07/2023 4:14 PM
County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 11/08/2023 8:34 AM
County Manager's Office Amy Patterson Level 4 County Manager Review Completed 11/08/2023 4:57 PM
Board of County Commissioners Geoffrey Willig Meeting Pending 11/14/2023 9:00 AM
16.E.5
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SETTLEMENT AGREEMENT AND RELEASE
This Settlement Agreement and Release executed by COLLIER COUNTY (the
“Employer”) and __________________ (the “Employee”) is intended to effect the
extinguishment of all obligations between the parties for and in consideration of any and all
claims for past due salary, overtime wages, remittances and all other sums from the
Employer made by the Employee up, through and including the date of execution of this
Release arising from or relating to the Employer’s classification status of the Employee as
exempt under the Fair Labor Standards Act (“FLSA”). The Employer and Employee hereby
covenant and agree on the following in exchange for the consideration paid to the Employee
hereunder, as well as, their promises to release one another as set forth herein.
A. The Fair Labor Standards Act (“FLSA”) and its regulations provide, in part,
standards for certain job classifications to be exempt from overtime compensation.
B. An investigation was conducted by the Department of Labor, Wage and Hour
Division (WHD) between December 2022 and June 2023 into the FLSA status of
employees in the title of EMS Battalion Chief. At the conclusion of the process, it
was determined that EMS Battalion Chiefs, previously not subject to the FLSA
overtime provisions, should have been classified as non-exempt and eligible for
overtime compensation pursuant to FLSA regulations.
C. The parties agree that the Employee performed work that would entitle him/her to
payment of actual overtime wages for the period between July 3, 2021, and June 30,
2023, resulting from the misclassification of his/her status under the FLSA in the
amount of ____________. The Employee was reclassified as non-exempt on July 1,
2023. Payment of the unpaid overtime wage shall be reimbursed to the employee no
later than the two pay periods following the execution of this Agreement.
D. The Employee agrees that the amount set forth in Paragraph C above represents full
payment for all hours worked over forty (40) hours per week for the period noted
during his/her employment with the Employer and that he/she has no record(s) to
indicate that he/she worked any additional hours for which he/she was not properly
compensated. The Employee further agrees that he/she was paid at or in excess of
minimum wage for all hours worked for the two years identified herein.
E. The Employer and Employee further agree that it is appropriate to resolve any
potential claim(s) arising under the FLSA by entering into this agreement to
discharge all claims related thereto, subject to the terms and conditions set forth
herein. In the event that the Employee is not currently employed in one of the subject
classifications, this agreement pertains to that period of time in which the Employee
was so employed during the period between July 3, 2021, and June 30, 2023.
In consideration of payment of the above sum and the relinquishment of their
respective legal rights with reference to the aforementioned matter, each party expressly
releases the other, and their heirs and legal representatives, from all liability for such claims
and demands, and further releases, acquits and forever discharges each other, of and from
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Packet Pg. 1439 Attachment: EXHIBIT 1 - Settlement Agreement and Release EMS Battalion Chiefs (27121 : EMS Battalion Chief FLSA Settlement Agreements
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all manner of action and actions, suits, and controversies whatsoever, in law or in equity,
relating to the Employee’s actual classification status under the FLSA as non-exempt as it
pertains to the Employee’s wages and compensation earned from the Employer for the paid
period identified herein.
IN WITNESS WHEREOF, the parties, and or their duly authorized agents have
signed and sealed this Settlement Agreement and Release on the date set forth below.
ATTEST:
CRYSTAL K. KINZEL, CLERK BOARD OF COUNTY COMMISSIONERS
COLLIER COUNTY, FLORIDA
By:________________________ By:_____________________________
DEPUTY CLERK RICK LoCASTRO, CHAIRMAN
_______________________ ____________________________
Witness Signature Employee Signature
_______________________ Employee: ___________________
Witness Printed Name Print Name
Dated: _______________________
_________________________
Witness Signature
_________________________
Witness Printed Name
Approved as to form and legality:
______________________________
Colleen M. Greene
Managing Assistant County Attorney
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Packet Pg. 1440 Attachment: EXHIBIT 1 - Settlement Agreement and Release EMS Battalion Chiefs (27121 : EMS Battalion Chief FLSA Settlement Agreements