Employers with operations and employees in New York State should by now be aware that the first notice to all employees regarding their pay status, required by the N.Y. Wage Theft Prevention Act (WTPA), must be given by January 31, 2012, and annually from now on. If you have not given these notices by now, you should have plans to do so before the end of the month. Fisher & Phillips described the requirements imposed by the WTPA in an Alert that was distributed in April 2011.

While giving the required notices concerning wage and salary information is an absolute requirement, employers should also realize that doing so may well raise additional issues that have not been discussed as widely as the specific legal requirement that employers provide the notices. Employees who receive a written notice about their pay can probably be counted on to discuss with other employees at least the fact that they received the notice. Some employees will probably discuss the details included in the notices – "comparing notes," so to speak, about their relative compensation with their fellow employees.