CRNA Overtime Under OBBBA: Are You Actually Eligible?

A few weeks back, I was wedged into a middle seat, half‑listening to the safety demo and half‑listening to the Doctor two rows up debating whether her “no tax on overtime” applied to call pay. Cue the beverage cart. Cue me whispering, “if it sounds too good to be true, it probably is.”

Here’s the clean version—what counts, who qualifies, and exactly how to get the paper trail you’ll need at tax time.

TL;DR (read this in between cases)

Under the One, Big, Beautiful Bill Act, eligible workers can deduct the FLSA (Fair Labor Standards Act) overtime premium (the extra 0.5× in time‑and‑a‑half) up to $12,500 (single) or $25,000 (MFJ) for 2025–2028, with MAGI phase‑outs at $150k/$300k and joint filing required if married. Details: IRS Fact Sheet FS‑2025‑03 and IRS Provisions Page.
Many staff CRNAs are FLSA‑exempt under the learned professional exemption—if truly exempt and salaried, there’s no FLSA overtime, hence no eligible premium to deduct. See DOL Fact Sheet 17D and DOL Fact Sheet 17N (Nurses).
Qualified overtime means the extra 0.5× premium required by FLSA—not call pay or general shift diff. See 29 CFR 778.110 and 29 CFR Part 778.

What actually counts as “overtime” here (and what doesn’t)

The OBBBA deduction targets qualified overtime compensation that exceeds your regular rate—i.e., the extra 50% premium under FLSA’s time‑and‑a‑half. That’s not the entire OT pay; it’s just the half‑time premium. For the legal phrasing and examples, see IRS FS‑2025‑03 and 29 CFR 778.110.

Example: If your regular rate is $150/hr and you worked 10 FLSA overtime hours, your gross overtime pay looks like $ 150 × 10 (straight) + $ 75 × 10 (premium). The eligible portion is the $750 premium, subject to caps and phase-outs. (See DOL Regular Rate Explainer and 29 CFR 778.110.)

“Am I even eligible?”—the CRNA reality check

Many staff CRNAs meet the learned professional exemption and are paid on a salary basis, so FLSA overtime doesn’t apply—which means there’s no FLSA premium to deduct. Nurses guidance is here: DOL 17N (Nurses) and the general professional exemption is here: DOL 17D. For the primary duty and advanced‑knowledge tests, see 29 CFR §541.301.

Hourly CRNAs, travelers, or roles expressly non‑exempt under hospital policy may have qualifying OT—but only the premium portion. If you’re unsure, confirm with HR which pay code maps to the FLSA premium and whether they will furnish a year‑end statement of qualified overtime compensation (see IRS reporting note below): IRS FS‑2025‑03.

The paystub decoder (copy/paste this to HR/Payroll)

“For the OBBBA ‘No Tax on Overtime’ deduction, please confirm which pay code(s) represent the FLSA‑mandated overtime premium (the extra 0.5×) and provide my calendar‑year total on my W‑2 or a year‑end statement of qualified overtime compensation.”

Why this exact phrasing? Because employers/payors must furnish statements and file information returns showing the total qualified overtime under the IRS’s reporting requirements: IRS FS‑2025‑03.

MAGI landmines (and how to step around them)

The deduction phases out at $150k single / $300k MFJ and requires joint filing if married. If you’re near the line, use levers like pre‑tax 403(b)/457, HSA contributions, and (for 1099 CRNAs) reasonable S‑Corp salary to keep MAGI in range. IRS details: IRS FS‑2025‑03. For the plan mechanics, start here: 403(b) vs. 457 for CRNAs, S‑Corp + HSA strategy, OBBBA Overview for CRNAs, and W‑2 vs 1099 for CRNAs.

Quick myths you probably keep hearing at the breakroom coffee pot

“All my OT is tax‑free.” Nope—only the FLSA premium portion is eligible, within caps and income limits. Source: IRS FS‑2025‑03.
“My call pay qualifies.” Not unless it truly meets the FLSA overtime premium definition; standard call/shift diffs generally don’t count. See 29 CFR Part 778.
“I’ll claim it even if I’m exempt.” If you’re exempt, there is no FLSA overtime to begin with. See DOL 17N.

CRNAs and the FLSA line in the sand

Here’s the kicker: most staff CRNAs are tagged “exempt” under the FLSA’s learned professional exemption—salary basis, advanced knowledge, all the boxes checked. If that’s you, there is no statutory overtime and therefore no FLSA premium to deduct. But not every role wears that label. Hourly CRNAs, per-diem travelers, or anyone a hospital classifies as non-exempt under its pay policies may still rack up bona fide FLSA overtime. That’s when the extra half-time premium—the $75 on top of the $150, in our example—becomes eligible for the OBBBA deduction. Translation: unless your paystub shows a separate overtime premium line tied to FLSA rules, chances are you’re exempt and out of luck on this one.