Washington's Overtime-Exempt Salary Floor Hits $92,196 Jan. 1 at 51+ Employees
L&I's 2027 figures move the multiplier for large employers from 2.25 to 2.5 times the minimum wage. Salaried BCBAs and clinical directors below the line need a raise or overtime pay from January 1.
Washington's Department of Labor & Industries published its 2027 figures on September 30, 2026. From January 1, 2027, an employer with 51 or more employees must pay an exempt worker "at least $1,773.00 a week ($92,196.00 a year)" to keep them exempt from overtime. That's the scheduled step from 2.25 to 2.5 times the minimum wage, on top of a 3.5% minimum wage increase to $17.73.
Why it's a bigger jump than usual
Most years, the threshold rises only with inflation. This year the multiplier changes too. At today's 2.25 times the $17.13 minimum, the floor is $1,541.70 a week. On January 1 it rises by $231.30 a week, about $12,000 a year, for large employers. L&I says "the multiplier is not scheduled to increase beyond 2.5."
Smaller employers get a year's grace. With 50 or fewer workers the multiplier "remains at 2.25 in 2027," which means "$1,595.70 a week ($82,976.40 a year)." It rises to 2.5 in 2028.
Where it lands in an ABA practice
The salary test applies to anyone treated as exempt under the executive, administrative or professional exemptions. In a practice, that's typically salaried BCBAs, clinical directors, office managers and billing leads. An exempt employee paid below the new floor isn't exempt from January 1. They're owed overtime for hours over 40 in a week, and that includes report writing and parent calls done at home. Hourly RBTs aren't affected by the salary test. Their floor is the new $17.73 minimum, or a higher city rate in Seattle, SeaTac, Tukwila, Renton, Bellingham, Everett, Burien and unincorporated King County.
The limits
L&I's release gives the thresholds and the 51-employee line but doesn't explain how employees are counted. Before relying on the small-employer figure, confirm with L&I's overtime rules how part-time and out-of-state staff count. Meeting the salary is necessary but not enough. The job duties still have to fit an exemption.
What you must know or do
- Owners: confirm whether you're over or under 51 employees as L&I counts them. That decides whether your number is $92,196 or $82,976.40.
- Owners and HR: pull the list of every salaried, exempt employee and their 2027 base pay. Anyone below the floor needs one of two decisions before the first January payroll: a raise to the floor, or reclassification to non-exempt with time tracking and overtime.
- If you reclassify a BCBA: set up time capture that includes off-site documentation and caregiver calls, since that's where unrecorded overtime piles up.
- Payroll: update RBT pay floors to $17.73, or your city's rate, for work from January 1.