How Case Managers Can Avoid Off-the-Clock Work: Operational Changes That Reduce Wage Risk

Stop Paying for Hidden Work: Practical operational changes departments can deploy now to prevent off-the-clock labor

If your department employs case managers, you already know the risk: unrecorded travel, end-of-day documentation done at home, or ad-hoc client calls that push nonexempt staff into unpaid overtime. In 2026 federal enforcement and recent court outcomes make this a top operational priority for HR and operations leaders. This article gives specific job-design and scheduling recommendations that reduce wage risk, improve morale, and keep your department compliant.

Why this matters now (short version)

Late 2025 and early 2026 saw sharper U.S. Department of Labor enforcement of timekeeping and overtime rules for nonexempt workers, especially in direct care and case-work roles. A high-profile example in January 2026 involved a multicounty provider in Wisconsin that agreed to pay more than $160,000 for failing to record and pay case managers for time worked outside recorded hours. That case underscores two facts:

• Title and intentions don’t protect you: labeling a role as "case manager" does not remove overtime obligations if the role is nonexempt.
• Administrative design and schedules create risk: lack of protected documentation time, travel rules, and weak approval flows are common drivers of off-the-clock work.

Inverted-pyramid summary: Key operational levers

1. Clarify exemption and pay status for every role (nonexempt vs exempt).
2. Redesign job tasks so core client work and predictable admin time are scheduled and auditable.
3. Protect administrative time on the schedule—daily blocks for documentation and follow-up.
4. Implement time-capture controls (mobile clocking, geofencing, audit trails) and clear after-hours rules.
5. Use supervision and auditing to catch unrecorded time and approve preapproved overtime.

A recent case study: What went wrong and what we learned

The December 2025 consent judgment involving North Central Health Care shows typical patterns that lead to wage exposure. Investigators found case managers worked unrecorded hours—including time spent documenting work and travel between clients—and were not paid required overtime for hours over 40 in a workweek. The judgment required back wages and liquidated damages to affected employees.

"The Department’s investigation found case managers were working unrecorded hours, and the employer failed to record and pay for all hours worked, including overtime."

Lessons:

• Task fragmentation (client visits + documentation + travel) without scheduled admin time drives off-the-clock work.
• Passive timekeeping (expecting staff to remember to clock in/out) fails when workloads spike.
• Supervisory review and staffing models that ignore travel and documentation create chronic overtime.

Operational changes: Job-design recommendations

Start with job design—what tasks are part of the workload and how much predictable time do they require? Below are concrete changes you can implement.

1. Break roles into measurable task blocks

Define the role as discrete, measurable task types with associated average time. For example:

• Initial intake visit: 90 minutes (including travel)
• Standard home visit: 60 minutes (30 min visit + 20 min travel + 10 min documentation)
• Phone follow-up: 15 minutes
• Daily administrative documentation: 60 minutes scheduled at the end of the day

Use time-and-motion data (small sampling of observed cases) to validate these averages. Capture the data in job descriptions and staffing models so managers can predict workload.

2. Standardize documentation expectations—and make time for it

Clear, standardized documentation templates reduce the time required to complete records. But templates alone aren’t enough—schedule protected documentation blocks as part of the shift so staff don’t have to finish notes off the clock.

• Set a minimum protected documentation block: e.g., 45–60 minutes per 8-hour day, or prorated for part time.
• Require documentation to be completed during paid time; prohibit expectation of completing records at home unless overtime is authorized.

3. Account for travel explicitly in job design

Treat travel between client sites and to/from the first/last client as compensable work when it occurs in the workday. Build travel time into daily schedules instead of treating it as incidental. Create routing templates that balance caseload and travel time.

4. Cap caseloads using a capacity formula

Use a formula that converts task minutes into weekly capacity. Example model:

1. Calculate total available paid minutes per week per case manager (e.g., 40 hours = 2,400 minutes).
2. Subtract protected allowances (documentation, meetings, admin): e.g., 5 hours/week = 300 minutes.
3. Remaining minutes are direct client capacity. Divide by average minutes per client interaction to set caseload caps.

Example: 2,400 – 300 = 2,100 minutes. If average contact (including travel and documentation) = 90 minutes, weekly capacity = 23 contacts. Multiply by average frequency of contact to determine caseload cap.

Scheduling recommendations to prevent off-the-clock hours

Scheduling controls are your most immediate lever to stop unpaid overtime. Below are practical prescriptions you can apply today.

1. Use shift templates with built-in admin time

Create shift templates that integrate client-facing time, travel, and protected admin time. Example 8-hour field shift:

• 08:15–08:30: Clock-in/briefing
• 08:30–12:00: Client visits (two visits)
• 12:00–12:30: Paid lunch
• 12:30–15:30: Client visits (two visits)
• 15:30–16:30: Protected documentation time

Require schedule adherence unless preapproved changes are entered in the LMS/HR system.

2. Implement a preapproved overtime policy

Unplanned overtime is a primary trigger of wage claims. Require managers to preapprove overtime via your scheduling system. For emergencies, require same-day supervisor review and a written explanation attached to the time entry.

3. Create buffer staffing for predictable peaks

Use historical data to identify predictable peak periods (e.g., first and third weeks of the month, or seasonal case spikes). Staff a small pool of float case managers or allow overtime only when float capacity is exhausted.

4. Protect end-of-day and evening boundaries

Set clear policy and technical controls around after-hours work. That includes:

• Blocking nonurgent system notifications after scheduled shifts
• Defining who can expect contacts outside work hours
• Requiring paid overtime if work continues past scheduled time and was not preapproved

Time tracking and technology: best practices (2026-ready)

Modern time systems can reduce wage risk if configured correctly. Use these controls while guarding against creating new expectations of always-on work.

1. mobile clock-in/out with tamper-evident audit trails

Deploy mobile clock-in/out that records timestamps and provides audit logs, but avoid punitive measures that prompt employees to clock out and continue working. The objective is accurate records, not forcing time underground.

2. Geofencing and travel triggers (use with caution)

Geofencing that auto-clocks travelers in/out can be effective for field staff. Use it to calculate travel time fairly, but pair it with privacy policies and clear consent. Make geofence edge cases a supervisory exception review.

3. AI-powered documentation assistants to reduce after-hours work

By 2026, many departments use AI-assisted notes and smart templates to cut documentation time 20–40%. Implement these tools with guardrails so they do not encourage higher caseload expectations—productivity gains should translate to reduced overtime and improved job satisfaction, not more unpaid work.

4. Integrate scheduling, timekeeping, and payroll

End-to-end integration prevents manual errors that lead to unpaid hours. Validate the flow with weekly audits that reconcile scheduled hours, clocked hours, and payroll.

Supervision, audits, and compliance routines

Operational controls are only as good as supervision and oversight. Build routines into manager workflows:

• Weekly time audits: Managers review weekly timecards for anomalies (late clock-ins with extra work coded as "not clocked").
• Monthly overtime heatmaps: Use dashboards to identify who consistently works unpaid hours and why.
• Quarterly job-task reviews: Validate that time standards still reflect reality; revise job design as client complexity or travel patterns change.
• Investigation and remediation protocol: If unrecorded time is found, correct pay immediately and review scheduling practices to prevent recurrence.

Training and culture: the human layer

Operational tools fail without clear expectations and trust. Your training program should:

• Teach what counts as compensable time (travel, documentation, phone calls) and the legal risk of off-the-clock work.
• Train managers on how to approve overtime and restructure workloads to avoid recurring unauthorized overtime.
• Reward accurate timekeeping and transparent escalation of workload pressure.
• Encourage reporting workload pressure and protect employees who surface chronic understaffing issues.

Sample implementation roadmap (60–90 days)

Deploy changes in a clear, phased way to get early wins and avoid disruption.

1. Week 1–2: Audit current timekeeping, caseloads, and most recent overtime incidents. Identify top 10 outlier employees and supervisors.
2. Week 3–4: Define task standards and update job descriptions with time allocations. Draft protected documentation policy.
3. Week 5–6: Configure scheduling templates and enable protected admin blocks in the scheduling tool. Pilot with one team.
4. Week 7–8: Roll out mobile time capture with geofencing for the pilot team, train staff, and deploy AI-assisted notes in beta.
5. Week 9–12: Scale to remaining teams, implement weekly audits, and publish a manager dashboard tracking overtime and caseload capacity.

Legal and policy considerations (what HR must confirm)

Before changing schedules or time systems, consult with employment counsel. Key legal checkpoints:

• Ensure pay classifications are accurate (misclassification is a major risk).
• Confirm your state’s travel and meal break rules—some states have stricter standards than the FLSA.
• For unionized workplaces, coordinate changes with collective bargaining agreements.
• Document remediation and make back-pay corrections if audits reveal unpaid time.

Advanced strategies and 2026 trends to consider

As enforcement and technology evolve in 2026, forward-looking departments are adopting several advanced strategies:

• Predictive workload modeling: Use historical event data to forecast surges and schedule float resources before overtime is required.
• Outcome-based scheduling pilots: In roles where outcomes, not hours, matter, test blended pay models with explicit overtime protections.
• Rightsizing AI: Use AI to pre-draft documentation and route tasks, but measure time savings and ensure they reduce—and do not mask—compensable work.
• Transparent wage-risk dashboards: Share high-level overtime metrics with frontline teams to align incentives and improve trust.

Key takeaways (Actionable checklist)

• Classify every role and confirm nonexempt/exempt status.
• Schedule protected documentation time as paid work.
• Measure task durations, include travel in schedules, and set caseload caps using a capacity formula.
• Control overtime with preapproval policies and a float pool for predictable peaks.
• Track time with audit-capable tools and reconcile schedules weekly.
• Train managers and staff on compensable time rules and create a culture of reporting workload pressure.

Final thought: Preventing off-the-clock work is operational, not just legal

Stopping unpaid overtime for case managers requires aligned job design, scheduling discipline, timekeeping accuracy, and active supervision. The legal backdrop in early 2026 makes these operational changes urgent—but they also improve employee wellbeing, reduce turnover, and produce more accurate budgeting.

Call to action

If you manage or administer departments with case managers, start with a focused 30-minute wage-risk audit. We'll help you identify the top three schedule and job-design fixes that will stop off-the-clock work immediately. Contact your HR operations lead or schedule an audit with departments.site today to get a prioritized implementation plan and a ready-to-use protected documentation template.

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