complianceoperationshealthcare

Avoiding Pay Disputes: Best Practices for Timekeeping in Multi‑County Care Partnerships

UUnknown

2026-02-20

10 min read

A 2026 operational playbook to prevent DOL pay disputes in multi‑county care partnerships with audits, policy, tech and training.

Stop Pay Disputes Before They Start: A Practical Timekeeping Playbook for Multi‑County Care Partnerships

Hook: If you run or operate a multi‑county care partnership, one missed punch, an undocumented case note after hours, or an inconsistent overtime approval can trigger costly back‑pay claims and federal scrutiny. The December 2025 consent judgment against a Wisconsin multicounty medical care partnership — ordered to pay $162,486 to 68 case managers after a Department of Labor investigation found unrecorded hours and unpaid overtime — shows the real cost of weak timekeeping.

Executive summary — what matters now (inverted pyramid)

In 2026 the Wage and Hour Division is focused on detecting off‑the‑clock work, overtime miscalculation, and missing recordkeeping. Multi‑county care providers are high‑risk because of decentralized payroll, multiple funding streams, and offsite casework. This playbook gives an operational plan you can implement in 60–120 days to harden timekeeping, create clear overtime approval workflows, train staff and supervisors, and build an audit trail that prevents DOL investigations like the Wisconsin case.

Key takeaways

Centralize or standardize timekeeping across counties with a single source of truth or tightly governed interfaces.
Stop off‑the‑clock work with clear policies, pre‑approval, spot audits and immutable audit logs.
Train and certify case managers and supervisors on compensable time, overtime rules and documentation standards.
Automate alerts for overtime thresholds and unusual patterns using AI anomaly detection in 2026 tools.
Document remediation immediately when gaps appear and involve counsel for disclosure options.

Why the Wisconsin judgment matters to multi‑county operators

On Dec. 4, 2025, a federal consent judgment required North Central Health Care to pay $81,243 in back wages and an equal amount in liquidated damages to 68 case managers after the U.S. Department of Labor’s Wage and Hour Division found that case managers worked unrecorded hours and were not paid overtime for work over 40 hours per week between June 17, 2021, and June 16, 2023.

Under the FLSA, employers must pay nonexempt employees no less than time and one‑half their regular rate of pay for all hours worked over 40 in a workweek.

This case is a concrete example of three systemic failures that commonly exist in multi‑county operations: poor recordkeeping, ambiguous policies on compensable time, and weak supervisory approvals. Any multi‑county partnership that tolerates inconsistent time capture or retroactive, undocumented overtime approvals is at risk.

Operational playbook — 9 tactical pillars to prevent pay disputes and DOL investigations

The following pillars form a pragmatic roadmap. Each pillar includes specific actions, timelines and measurable outcomes.

1. Governance: designate a single timekeeping owner and cross‑functional steering committee

Action steps:

Appoint a Timekeeping Program Owner (TP0) — senior HR or operations leader accountable for policy, system choice, training and audits.
Create a steering committee: HR, Payroll, Legal, IT, County HR reps and an operational lead for case management.
Set KPIs: time capture compliance rate (target >99%), unresolved missed punches, average overtime hours by employee class, audit exception rate.

Timeline: 0–14 days to assign roles and KPIs.

2. Policy: publish a clear, binding pay and timekeeping policy

Include these essentials in a single, organization‑wide policy that supersedes county variability where legally permissible:

Definition of compensable time (travel, documentation, phone calls, training, on‑call work).
Overtime rules, including rounding rules, overtime calculation and regular rate components.
Pre‑approval requirements for overtime and a defined retro‑approval process with documented justification.
Consequences for failing to record time or for knowingly working off‑the‑clock.
Record retention standards: maintain payroll records for at least 3 years and basic time records for 2 years; retain copies of audits and corrective pay determinations for 6 years to limit exposure.

Timeline: 0–30 days to issue a policy draft; 30–60 days to finalize after legal and county input.

3. Timekeeping system: pick a tamper‑evident, auditable solution

Selection criteria for 2026 tools:

Immutable audit logs with user id, timestamp and change history exportable in CSV and PDF.
Geofencing or verified locations for field case managers, with offline/mobile logging and automatic reconciliation.
Integration with EHRs and case documentation systems to cross‑validate activity timestamps.
AI anomaly detection that flags sudden increases in after‑hours edits, frequent retroactive edits, or repeated missed punches.
SSO and role‑based access control to protect integrity and privacy (HIPAA considerations).

Quick win: if a single system is not feasible, deploy a standardized timekeeping API or middleware to normalize and centralize logs.

Timeline: 30–90 days for selection and pilot; 90–180 days for full rollout (pilot critical).

4. Overtime approval workflow: make approvals auditable and proactive

Do not permit verbal or retroactive approvals without documentation. Implement the following:

Pre‑approval policy requiring submission through the timekeeping system for non‑emergency overtime.
Emergency exceptions allowed only with same‑day documented supervisor approval recorded in the system.
Automatic alerts when an employee reaches 35 hours in a week that notify supervisor and payroll for pre‑emptive review.
Retroactive approval route that triggers an audit ticket and requires HR sign‑off with explanation.

Timeline: 7–30 days to configure workflows and alerts; immediate enforcement post‑launch.

5. Training & certification: mandatory, role‑based learning with assessments

Training must be targeted, tracked, and recurring:

New‑hire certification for case managers and supervisors covering compensable time examples, time entry, overtime approvals and consequences for violations.
Quarterly refreshers for supervisors focusing on approvals, flags, and how to conduct spot audits.
Scenario‑based eLearning (documented timekeeping scenarios with graded outcomes) and annual attestation of understanding.
Maintain training completion records linked to personnel files for audit defense.

Timeline: develop core modules in 30–60 days; roll out mandatory completion within 90 days.

6. Audit program: proactive self‑audits and continuous monitoring

Implement a layered audit approach:

Daily/weekly automated exception reports (missed punches, retro edits, overtime spikes).
Monthly sample audits of 5–10% of case manager timecards, emphasizing after‑hours documentation and travel time.
Quarterly deeper audits including payroll reconciliation, regular rate calculation review and supervisory approval sampling.
Annual comprehensive FLSA compliance audit performed with external counsel or specialist.

Metrics to track: percentage of exceptions resolved within 7 days, number of retro approvals, amount paid in corrective adjustments.

Timeline: build automated reports in 14–30 days; establish audit cadence immediately.

7. Remediation and voluntary correction

When audits reveal underpayments:

Calculate back pay promptly using the regular rate and overtime multiplier (time & one‑half) per FLSA rules.
Document the remediation plan: payments, manager coaching, process fixes and prevention steps.
Consult employment counsel about whether to voluntarily disclose to the DOL to mitigate liquidated damages (legal strategy varies by circumstance).

Timeline: remediate within a single payroll cycle where possible; document all steps.

8. Culture and enforcement: leadership sets nonnegotiable expectations

Operational controls fail without culture change. Do this:

Leadership message: zero tolerance for off‑the‑clock work and clear protection for employees who report payroll errors.
Reward supervisors who maintain clean audit records; tie a portion of performance reviews to timekeeping KPIs.
Provide an anonymous reporting channel for employees and guarantee no retaliation.

Timeline: immediate and continuous.

9. Multi‑county coordination: harmonize differences and close integration gaps

Multi‑county partnerships often struggle with disparate payroll calendars, bargaining agreements and county‑level HR practices. Reduce risk by:

Mapping all payroll systems, collective bargaining provisions and county policies that affect compensable time.
Negotiating a master timekeeping protocol in partnership agreements that requires counties to conform to minimum uniform standards.
Implementing a central reconciliation hub (middleware) to normalize time data from county systems.

Timeline: 30–120 days for mapping and agreements; 90–270 days for system integration.

Compensable time: high‑risk activities you must document clearly

Case managers and field staff commonly perform work that employers misclassify as noncompensable. Make sure policy and training cover these examples explicitly:

Home visits, travel between clients during the workday (not commute to first site), and travel that is part of the day’s duties.
Post‑shift documentation: notes entered after leaving the client site; if work is required, it’s compensable.
On‑call time vs. waiting time: document expectations and pay rules in policy.
Phone calls, text messaging, telehealth documentation completed outside scheduled hours.
Mandatory trainings and supervisory meetings, including remote sessions.

Technology and 2026 trends to leverage

Late 2025 and early 2026 saw a wave of innovation in workforce compliance tools. Use these responsibly:

AI anomaly detection: flags unusual editing behavior, pattern changes, and likely off‑the‑clock work for human review.
Immutable ledgers: tamper‑evident logs that record every change and preserve the original entry.
EHR and case system integration: cross‑validate timestamps from clinical records with timecard entries to detect missed compensable activities.
Geofencing and mobile verification: useful for field teams but require privacy and HIPAA compliance policies.

Note: technology reduces risk but does not replace policy, training and supervisory enforcement.

Sample remediation calculation (quick example)

Scenario: A case manager was not paid 10 hours of overtime over a sample week. Their regular rate (including nondiscretionary bonuses) is $30/hour.

Overtime rate = $30 × 1.5 = $45/hour
Back pay = 10 × $45 = $450
Liquidated damages (if DOL finds willful violation) could equal back pay. Mitigate by prompt self‑remediation and counsel assistance.

Checklist: first 60 days implementation

Day 1–7: Appoint TPO and steering committee. Publish leadership message.
Day 7–30: Issue interim timekeeping policy and CEO directive. Configure automated exception reports.
Day 14–45: Pilot or standardize timekeeping system for highest‑risk teams (case managers).
Day 30–60: Roll out mandatory training for case managers and supervisors. Begin weekly exception reviews.
Day 60–90: Launch quarterly audit calendar and remediation process.

What to do if you discover an exposure

Stop the error: fix payroll moving forward and prevent further off‑the‑clock work.
Quantify the exposure via a focused audit and prepare remediation payments.
Involve employment counsel to evaluate disclosure options and litigation risk.
Document everything: audit methodology, remediation, communications and policy changes.
Communicate with employees transparently and process corrective pay quickly.

Key facts: the DOL found that between June 17, 2021 and June 16, 2023, 68 case managers performed unrecorded compensable work that was not paid as overtime. The consent judgment required payment of $81,243 in back wages and an equal amount in liquidated damages.

Operational lessons:

Relying on decentralized logs and informal supervisor approvals created gaps that the DOL could quantify.
Poorly defined compensable time (especially documentation done after client visits) was the top driver of unrecorded work.
Remediation after discovery likely reduced enforcement severity, but the judgment still imposed significant costs.

KPIs to track long‑term

Time capture compliance (% of shifts with verified punches/documentation).
Retroactive edits per month and average time between edit and discovery.
Overtime hours per full‑time equivalent (FTE) and % pre‑approved.
Audit exception resolution time and remediation dollar amount.
Training completion and certification pass rates.

Final recommendations — executive checklist

Mandate a single timekeeping owner and publish an organization‑wide policy within 30 days.
Standardize time capture for case managers, using mobile verification and audit logs, and integrate with case systems.
Require pre‑approval for overtime and set automated alerts at 35 hours/week.
Deliver role‑based training with certification and keep records.
Run proactive audits and remediate quickly; consult counsel when exposure exceeds a material threshold.

Closing: why acting now matters (2026 urgency)

Regulatory attention to off‑the‑clock work and recordkeeping increased through late 2025 and into 2026, and enforcement dollars are focused on sectors with remote and field employees. Multi‑county care partnerships are uniquely exposed: decentralized operations, multiple payroll systems, and high volumes of after‑hours documentation create fertile ground for violations.

Preventive investment in policy, training, technology and audits is far less costly than a DOL investigation, back wages and liquidated damages — and less damaging to employee trust. Use this playbook to build an auditable, teachable and enforceable timekeeping program that protects your people and your mission.

Call to action

Ready to implement a compliance‑grade timekeeping program? Contact specialty.info to schedule a 30‑minute readiness assessment, download our Timekeeping & Overtime Toolkit, or find vetted payroll and compliance specialists who have implemented these exact controls for multi‑county healthcare providers.

Unknown

Contributor

Senior editor and content strategist. Writing about technology, design, and the future of digital media. Follow along for deep dives into the industry's moving parts.