The 15% PAGA cap, for the staff §515.8 doesn’t exempt.
MicroForensics, built for heads of school and business officers at mid-size California private schools — single-campus employers sitting squarely in the 25–250 band. The exposure isn’t the faculty; it’s the hourly staff: aides, aftercare, custodial, food service, front office. Runs on the generic payroll timeclock the school already uses — FACTS and Blackbaud stay untouched. Reviewed by named California labor counsel.
Request a discovery call→For the full MicroForensics walkthrough — statute math, cap delta, four-pillar architecture — see the parent page. This page covers the industry-specific shape.
Three structural reasons private-school PAGA exposure rises in 2026–2027.
§515.8 exempts teachers — and expressly excludes everyone else.
Aides, aftercare, custodial, food service, and front-office staff sit outside the private-school teacher exemption by the statute’s own terms — hourly employees under the full meal, rest, overtime, and wage-statement machinery. They’re a minority of a school’s headcount and nearly all of its wage-and-hour exposure. The shared Education & Childcare filing category is up 27.1% year over year (Ankura/LWDA data through mid-2026) — directional, since no school-only split exists.
Supervising kids is how the duty-free lunch quietly doesn’t happen.
An aide can’t leave a classroom, and an aftercare lead can’t leave the pickup line, when the §512 fifth-hour window arrives. Donohue v. AMN Services (Cal. 2021) makes a missed, short, or late meal period in the time records a rebuttable presumption of violation — and time data alone can’t rebut it. The contemporaneous attestation, captured when the exception occurs, is the rebuttal evidence the court contemplated.
The teacher salary floor is pegged to district pay — and it moves.
§515.8’s floor tracks public salary schedules: a full-time teacher must earn at least 100% of the lowest credentialed-teacher salary offered by any California district, or 70% of the lowest schedule salary in the district — or county office of education — where the school sits. When districts raise pay, the floor moves — and a teacher paid below it falls out of the exemption, hourly rules attaching whatever the employment letter says. Lower-tuition and religious schools hit this trap without noticing.
The private-school stack we orchestrate.
FACTS & Blackbaud, untouched
FACTS SIS — the former RenWeb — and Blackbaud run the student side: enrollment, grades, tuition. Neither carries a time sign-off, and neither needs to. MicroForensics builds the employment-side record and leaves the admin stack exactly where it is.
The generic timeclock
School payroll runs on generic gear — a wall clock or app feeding Gusto, QuickBooks, Paychex, or ADP. We integrate as a read-only consumer, reconcile §226 wage statements against the per-period attestation, and never replace the payroll run.
Per-payday sign-off, EN/ES
Every pay period, aides, aftercare, kitchen, and front-office staff attest — English or Spanish — that breaks were taken and hours are right. Fifth-hour alerts reach the office while coverage can still be sent. Every signature lands on a timestamped record reviewed by California labor counsel.
One statutory overlay reaches the whole campus: SB 553’s workplace-violence prevention requirements (Labor Code §6401.9, in force since July 1, 2024) apply to nearly every California employer, and a school — front office open to parents, pickup lines, aftercare — sits well outside the narrow exemptions. The written plan, training, and violent-incident log are dateable, documented obligations; the attestation surface that carries the break record carries the SB 553 acknowledgment too.
What these buyers ask first.
- 01
Our teachers are salaried and exempt. Doesn’t that cover the school?
It covers teachers — if the duties test is met and the salary floor holds. §515.8 pegs that floor to public district salary schedules: 100% of the lowest credentialed-teacher salary offered by any district, or 70% of the local district’s lowest schedule salary. It moves when districts raise pay, so exemption status is an annual check, not a hiring-day decision. And it never covered the aides, aftercare, custodial, food service, or front-office staff — which is where the exposure sits.
- 02
Aftercare and lunch duty run on part-timers. Does this really reach them?
Yes. Part-time hourly employees carry the same meal-and-rest machinery as full-timers — the rules turn on hours worked in the day, not on status. The structural problem is supervision: an aide watching a room can’t take a duty-free 30-minute lunch unless someone covers. Under Donohue v. AMN Services (Cal. 2021), a missed or late period in the time records is presumed a violation; the contemporaneous attestation, plus a fifth-hour alert that reaches the office in time to send coverage, is the rebuttal evidence the court contemplated.
- 03
We run FACTS (or Blackbaud). Can’t the attestation live there?
No — and we don’t try to put it there. FACTS SIS and Blackbaud run the student side of the school: enrollment, grades, tuition billing. Neither carries a per-pay-period time sign-off. MicroForensics rides the employment side — the payroll timeclock and payroll system the school already runs — as a read-only consumer, and routes the attestation each payday. The admin stack sees no change, and nobody relearns software.
- 04
The business office is two people and the board meets quarterly. Who actually runs this?
Floburn does. We build the flows on your existing timeclock and payroll, operate them, and update the rules as California law changes. The business officer becomes the audit-trail owner — the person who sees exceptions before payroll closes — not a compliance department. Nonprofit status changes none of the underlying wage-and-hour obligations, and a slow board isn’t a blocker: the two-week diagnostic stands on its own, and about a third of clients take the report and act on it themselves.
Free 30-minute discovery call.
A fit conversation, not a sales call. Tell us about your timekeeping and payroll stack, your headcount, and what’s prompting the conversation. We’ll tell you whether the diagnostic makes sense, which engagement structure fits your situation, and what to expect if you proceed.
Request a discovery call→MicroForensics is reviewed by named California labor and employment counsel. Counsel does not represent your company; you should retain your own counsel for advice specific to your situation.