Wage and Hour Division Compliance Strategies Evaluation

Prepared for
U.S. Department of Labor
Smiling employees

The mission of the Wage and Hour Division (WHD) of the U.S. Department of Labor (DOL) is to promote and comply with labor standards designed to protect and enhance workers’ welfare. These standards include the minimum wage, overtime, and child labor provisions of the Fair Labor Standards Act. Data, research, and evaluation inform WHD’s compliance strategies and help the agency use its limited resources to monitor and assess whether it is applying its strategies effectively and efficiently.

As part of this effort, DOL’s Chief Evaluation Office engaged Mathematica to support WHD with an evaluation of compliance strategies. We will design and conduct an outcomes assessment of WHD’s compliance strategies, including developing a framework for conducting ongoing assessments to support WHD’s continual learning and improvement, using a range of outcome measures. We will also develop design options for compliance assistance interventions that are informed by behavioral science. In addition, at DOL’s option, we may carry out an evaluation of the compliance assistance interventions. A technical working group will provide input at key stages of the project. Key deliverables include a report on the outcomes assessment of compliance strategies, a design report on behavioral compliance assistance interventions, and a public use data file.

Knowledge development tasks will provide the foundation for both study components. We will interview WHD staff and review WHD documents and databases to learn about the agency’s internal planning, targeting, and investigation processes. We will also conduct comprehensive external literature and database reviews. These activities will help us identify promising compliance strategies and compliance assistance strategies for evaluation.

For our outcomes assessment of compliance strategies, we will develop a systematic method to compare the strategies identified in the knowledge development task and select one or more strategies for evaluation. Our method will include developing (1) a logic model that shows how compliance strategies could affect an establishment’s decision making and compliance and (2) a conceptual model that shows likely channels for spillover effects based on relationships between firms. We will work with DOL to select strategies for evaluation based on DOL’s priority criteria, data needs, and data availability. We will then design and conduct an assessment of outcomes, changes in outcomes, or impacts associated with the selected strategies for targeted establishments, other establishments, and targeted industries and workers. In addition, we will develop a framework (such as a data dashboard) that WHD can use to support data-driven, continual improvement of compliance strategies and the refinement of strategic planning.

For the behavioral compliance assistance intervention design, we will identify and design evaluations to test cost-effective compliance assistance strategies. These strategies will be informed by behavioral science and will help us gauge increases in employers’ voluntary compliance. We will first work with WHD stakeholders to identify areas where program performance could be improved and then develop a logic model that includes (1) a process map describing the procedures to be modified by intervention options, (2) a behavioral map that shows behavioral bottlenecks and potential interventions to overcome them, and (3) the intermediate and final outcome measures to be used to track employer behaviors. We will propose options for compliance assistance interventions and designs for testing them (proposing randomized controlled trials where possible), based on research findings from the field, behavioral theory, lessons learned in other behavioral intervention research, and findings from earlier study tasks.

If DOL exercises the option, we will also conduct the behavioral intervention impact evaluation. The impact evaluation work will include coordinating with the national office and local offices, pilot testing, monitoring implementation, iterative evaluation, and reporting on findings.