Casa Nueva long ago settled on a system of pooling all tips from a given pay period and dividing them equally between all employees based on how many hours they worked that pay period. “What we truly believed in was that everybody, from the dishwasher, the prep cook, the cooks, the servers, provided the customer’s meal, so they should share in the tips,” said 25-year worker-owner Nancie Buerkel. Problem is, back in February, the Department of Labor issued “Field Assistance Bulletin No.