According to a former Bush administration official (now a Washington, D.C. lawyer who follows enforcement trends), the Department of Labor (DOL) is conducting more surprise wage-and-hour investigations than at any time in the recent past.
Afred J. Robinson Jr., who was acting administrator for the DOL's Wage and Hour Division (WHD) under George W. Bush, is now an attorney with Ogletree Deakins in the nation's capital.
Robinson said that WHD investigators will show up unannounced and seek the same documents they normally would seek had they followed pre-inspection notification procedures. Such documents include detailed information about the company's officers, employees (including independent contractors), finances and record-keeping compliance.
The lesson is obvious: Keep your records up to date, and in the phase used frequently by both human resource professionals and employment lawyers: "document, document, document."