A salaried employee — office manager, $52,000 a year, inherited from the previous administrator — worked 47 hours last week and was paid, as always, her flat salary with nothing added for the extra seven. The practice assumed a salary settled the question. It doesn't.

The administrator already has enough information to question the classification. The employee works the phones, checks patients in, takes copayments, covers the back office when it is short, settles friction between two front-desk staff and occasionally sits in on interviews. She supervises nobody. She sets no policy. She cannot hire or fire.

She has been classified exempt — treated as ineligible for overtime — for two years. But exempt status isn't established by paying a salary; it requires that the job's duties meet a legal test. Hers don't obviously meet it, and the facts strongly point toward misclassification.

Any unpaid overtime is the immediate problem. The broader problem surfaces that afternoon: almost none of the practice's position descriptions match what its people actually do, and several roles have no description at all.

Four HR decisions that are often blurred together

Practices often treat four separate HR decisions as if they were the same thing. Keeping them separate prevents mistakes in hiring, pay, accommodation, and overtime decisions.

1. Job analysis comes first: observe the work, talk with the employee and supervisor, review the workflow and compare their accounts with what the practice actually needs. Incumbents and supervisors often emphasize different parts of the role; both accounts are inputs, not the final answer.
2. The position description turns that analysis into a usable document: purpose, reporting line, essential and marginal functions, required and preferred qualifications, physical and environmental demands, and an accommodation statement. It describes the role, not the current employee. A description built around one person can become inaccurate the day that person leaves.
3. Job architecture or classification groups similar roles into job families, levels and pay grades so the practice can make consistent pay and promotion decisions.
4. Exemption classification applies federal and state wage-and-hour tests to the work and compensation arrangement. Two roles may sit in the same internal family while one is exempt and the other is not. The position description supports that analysis; it does not decide it.

Essential functions are verbs

The essential-functions section carries more weight than any generic summary of the role.

Title I of the ADA generally applies to private employers with 15 or more employees, though state disability laws may cover smaller practices. The ADA does not require a written position description. A description prepared before recruiting or interviewing can serve as evidence of the job's essential functions, but it is not controlling. The EEOC also considers the actual work, time spent, consequences of not performing a function, the number of people available to perform it and other evidence.²

Write functions as actions. Rooms patients, takes vital signs, enters the chief complaint and hands off to the clinician before the exam tells a manager what the job requires. Provides excellent clinical support describes an aspiration, not a function that can be evaluated in hiring or accommodation analysis.

Separate essential from marginal deliberately. A medical assistant who restocks the break room once a week is performing a marginal task; reassigning it during an accommodation process does not remove the core clinical work. If every duty appears in one undifferentiated list, the practice has made its own analysis harder.

Describe physical and communication demands through the work itself where possible: accesses exam rooms and workstations throughout the clinic; moves supplies weighing up to 25 pounds between storage and clinical areas; operates keyboards and examination equipment; exchanges information accurately with patients and colleagues using available communication methods. The Job Accommodation Network offers practical guidance for writing descriptions that support an individualized accommodation analysis.³

List a qualification as required only if the practice truly will not hire without it. Every credential that is merely preferred but listed as mandatory narrows the applicant pool. It also creates a consistency problem when the practice waives the requirement for one candidate but not another.

Exemption classification and the title trap

Most practice employees classified under the executive, administrative or learned-professional exemptions must meet three tests: salary basis, salary level, and actual job duties. A title or internal grade does not substitute for any of them.

Salary basis. The employee receives a predetermined amount that generally does not fluctuate with the quantity or quality of work, subject to the rules governing permitted deductions.

Salary level. The current federal threshold is $684 per week, or $35,568 annually, for most executive, administrative and professional employees. A separate $107,432 total-annual-compensation threshold applies to certain highly compensated employees, but compensation alone does not create an exemption; the employee must also satisfy the applicable salary and duties requirements. A 2024 federal rule would have raised the levels, but courts vacated it, and the Department of Labor issued a technical amendment in May 2026 restoring the 2019 regulatory text.⁴

As of July 2026, several states — including California, New York, Washington, Maine and Alaska — use higher salary levels or other more protective requirements. The practice must satisfy both federal law and the law of the state where the employee works, including any different duties tests or deduction rules. Verify the applicable standard when the classification is made and whenever the work location changes.

Duties. The executive exemption generally requires management as the primary duty, regular direction of at least two full-time equivalents and meaningful input into hiring, firing or other status decisions. The administrative exemption generally requires office or nonmanual work related to management or general business operations, together with discretion and independent judgment on significant matters.⁵

In a medical practice, the common classification mistakes are easy to recognize. A supervisor title with no direct reports does not satisfy the executive test. An office manager whose day is dominated by scheduling, payroll entry and phone coverage may not satisfy the administrative test merely because the role is important.

A registered nurse paid on a salary or fee basis may qualify for the learned-professional exemption when the duties and educational requirements satisfy the test. Registered nurses paid hourly generally remain overtime-eligible. LPNs and medical assistants ordinarily do not qualify under the learned-professional exemption because their roles generally do not require the prolonged specialized academic instruction contemplated by the rule.⁶

Close cases should be analyzed against the actual work, documented and revisited when duties drift. When a practice hires a remote employee in a new state, the wage-and-hour review belongs before the first payroll, not after a complaint.

Descriptions shift as work changes

A description can become inaccurate quickly when the practice changes systems, staffing models or service lines. Review a position description when the job changes, and also set a regular schedule for reviewing all descriptions.

Three types of events should trigger a review. 

1. The work changes: a new EHR, a different care-team model, a service line opens or closes, or a function is outsourced or brought back in house. 
2. An employee issue exposes drift: an accommodation request, a dispute about duties, onboarding that reveals undocumented work, or a role that has grown beyond its original scope. 
3. The scheduled review arrives: many practices adopt a two- or three-year cycle for comparing the full position library with the work employees actually perform.

Supervisors should review descriptions for their teams and flag drift. Incumbents can describe how the work is performed, understanding that their account is one source. Final responsibility for accepting a change — and deciding whether it requires a new compensation or exemption review — stays with the designated HR or administrative owner.

For a genuinely unfamiliar role, the Department of Labor-sponsored O*NET OnLine database can provide an occupational starting point before the practice customizes the description to its specialty mix, technology and care model.⁷

The operating payoff

Turnover may be attributed to pay or a manager. A wage-and-hour finding may be attributed to payroll. An accommodation dispute may be treated as an isolated employee issue. Often the problem started earlier: no one clearly defined the job, so later decisions about pay, duties, accommodation, and overtime rested on a weak foundation. MGMA reporting on staff turnover underscores why basic role design and management discipline remain practical retention work, not paperwork for its own sake.⁸

A current position description gives the practice a common reference point for hiring, training, pay, accommodation and classification. It will not answer every HR question, but it makes the next question easier to ask and much easier to document.

Notes

1. U.S. Department of Labor, Wage and Hour Division. "Fact Sheet #23: Overtime Pay Requirements of the FLSA." https://www.dol.gov/agencies/whd/fact-sheets/23-flsa-overtime-pay
2. U.S. Equal Employment Opportunity Commission. "The ADA: Your Responsibilities as an Employer" and "Small Employers and Reasonable Accommodation." https://www.eeoc.gov/publications/ada-your-responsibilities-employer and https://www.eeoc.gov/publications/small-employers-and-reasonable-accommodation
3. Job Accommodation Network. "Job Description Topics." https://askjan.org/topics/jobdesc.cfm
4. U.S. Department of Labor, Wage and Hour Division. "US Department of Labor announces technical amendment restoring regulations on exemptions for executive, administrative, professional employees." May 14, 2026; and "Fact Sheet #17H: Highly Compensated Employees." https://www.dol.gov/newsroom/releases/whd/whd20260514 and https://www.dol.gov/agencies/whd/fact-sheets/17h-overtime-highly-compensated
5. U.S. Department of Labor, Wage and Hour Division. "Fact Sheet #17B: Exemption for Executive Employees" and "Fact Sheet #17C: Exemption for Administrative Employees." https://www.dol.gov/agencies/whd/fact-sheets/17b-overtime-executive and https://www.dol.gov/agencies/whd/fact-sheets/17c-overtime-administrative
6. U.S. Department of Labor, Wage and Hour Division. "Fact Sheet #17N: Nurses and the Part 541 Exemptions Under the Fair Labor Standards Act." https://www.dol.gov/agencies/whd/fact-sheets/17n-overtime-nurses
7. U.S. Department of Labor. O*NET OnLine. https://www.onetonline.org
8. MGMA HR Insights. "Stabilized but not solved: Staff turnover in medical practices looking no better, no worse in 2026." May 28, 2026. https://www.mgma.com/mgma-stat/stabilized-but-not-solved-staff-turnover-in-2026