How a Wisconsin Medical Partnership Owes $162K — Lessons for Small Healthcare Employers

When off-the-clock minutes become a six-figure bill: what small healthcare employers must learn from a Wisconsin judgment

If you run a small clinic, community nursing program, or manage case managers, a federal consent judgment requiring a Wisconsin medical partnership to pay $162,486 should be a red flag. That judgment — entered Dec. 4, 2025 — resolved a U.S. Department of Labor Wage and Hour Division investigation that found 68 case managers were not paid for all hours worked, including overtime, between June 17, 2021 and June 16, 2023.

For many small healthcare providers, the pain points are familiar: mobile staff who document care after visits, lengthy travel between clients, and a workplace culture that discourages clocking extra minutes. The result can be costly: back wages, liquidated damages, legal fees, reputational damage, and repeated compliance scrutiny.

Quick summary — the Wisconsin case, in plain terms

The multicounty partnership doing business as North Central Health Care agreed to pay $81,243 in back wages and an equal amount in liquidated damages to 68 case managers after a DOL investigation found the employer had failed to record and pay all hours worked. The department’s complaint alleged violations of the Fair Labor Standards Act (FLSA) for both overtime pay and recordkeeping over a two-year period.

Key facts you should know:

• Employer: North Central Community Services Program and Affiliates (North Central Health Care).
• Employees affected: 68 case managers (nonexempt staff).
• Period under review: June 17, 2021–June 16, 2023.
• Amounts: $81,243 in back wages + $81,243 in liquidated damages = $162,486.
• Violation types: unpaid hours (off-the-clock work), overtime pay shortfalls, and inadequate recordkeeping under the FLSA.

Why this matters now: enforcement and 2026 trends

Between late 2024 and early 2026 the Department of Labor has stepped up enforcement of wage-and-hour rules, with a renewed focus on remote and mobile workforces typical in home health, community services, and case management. Enforcement priorities include:

• Accurate timekeeping for mobile employees and off-site work.
• Documentation of travel and post-shift tasks like charting or client follow-up.
• Proper classification of nonexempt versus exempt employees.
• Retaining electronic records that clearly show hours worked.

Technology vendors in 2026 are offering AI-assisted timekeeping, geofencing, and better payroll integrations — but technology alone isn't enough. Employers must pair tools with clear policies and training to avoid the very problems that triggered the Wisconsin case.

Root causes: how off-the-clock work happens in healthcare

The DOL's finding in the Wisconsin case is a case study in common, preventable failures. Below are the primary root causes you should examine in your own operation.

1. Field work and post-visit administrative time

Case managers, community nurses, and home health aides often complete documentation after they leave a visit. If you don't require that time to be recorded and paid, it becomes 'off-the-clock' work.

2. Unrecorded travel between clients

Travel that is part of the job (travel between assignments) is compensable under FLSA. Many employers fail to record or pay for this travel time consistently.

3. A workplace culture that discourages punching in/out

Managers who praise staff for staying late without recording time — or who implicitly expect after-hours charting without pay — create legal exposure.

4. Poor recordkeeping and manual timesheets

Handwritten timesheets, inconsistent approvals, and missing signatures give investigators a straightforward path to conclude hours were underreported.

5. Misunderstanding exempt vs. nonexempt rules

Some employers assume that clinical or supervisory titles mean exemption from overtime. Title alone doesn't protect a salary from overtime rules — duties and pay tests determine exemption.

Lessons from the Wisconsin judgment — three fundamentals

From a compliance perspective, the takeaway is simple but not easy: if employees work, you must record and pay for that time. The Wisconsin outcome also highlights three fundamentals:

1. Recordkeeping matters. The FLSA requires accurate records of hours worked. Weak records invite investigation and costly remedial measures.
2. Small hours add up. Individual unrecorded minutes over weeks and months produce large back-pay calculations fast.
3. Prevention is cheaper. A quarterly audit, clear policies, and basic tech often cost far less than a six-figure judgment.

Off-the-clock minutes become six-figure liabilities when a regulated enforcement agency reconstructs hours across years.

Practical, step-by-step compliance plan for small healthcare employers

Below is a prioritized, actionable plan you can implement in the next 90 days to reduce your risk of a wage violation like the Wisconsin case.

Step 1 — Launch a focused timekeeping audit (Week 1–4)

• Gather: timesheets, payroll reports, job descriptions, schedules, GPS or mobile clock logs, and any written policies on overtime, travel, and off-site work for the past 24 months.
• Sample: choose a representative sample of employees across case managers, nurses, and aides. Compare recorded hours to expected field schedules and client logs.
• Interview: confidentially ask staff about unpaid tasks (charting, travel, on-call time) and whether they feel pressured to underrecord.
• Identify gaps: look for consistent patterns of missing post-shift time or travel time between clients.

Step 2 — Fix policies and documentation (Week 2–6)

• Write or update a clear timekeeping policy requiring employees to record all work, including pre-shift, post-shift, travel between assignments, and mandatory training.
• Require electronic sign-off on timesheets with a supervisor attestation verifying that reported hours are complete and accurate.
• Document exceptions and approval flows for overtime — but remember: approval policies cannot lawfully deny payment for overtime already worked.

Step 3 — Deploy practical technology (Week 3–10)

• Choose a timekeeping tool that supports mobile clock-ins, timestamps, and exportable audit trails. In 2026, many vendors offer geofencing and AI flagging for missed clock-outs.
• Integrate timekeeping with payroll to eliminate manual entry errors.
• Train staff and supervisors on the tool; require daily or shift-end time confirmation.

Step 4 — Re-evaluate worker classification (Week 4–8)

• Use duties-and-salary tests to confirm exempt status where applicable. Titles alone don't determine exemption.
• When in doubt, classify conservatively as nonexempt and properly compensate overtime until you obtain legal clarity.

Step 5 — Train leaders and change culture (Week 4–12)

• Train supervisors on the legal obligation to pay for all hours worked and the risks of discouraging time reporting.
• Communicate to staff that the organization prefers to pay for extra time rather than penalize unreported work. Include this in your training and onboarding materials so new leaders understand expectations.

Step 6 — Establish ongoing compliance checks (Month 3+)

• Schedule quarterly audits that review a rotating sample of employees, cross-reference mobile logs, and check for unapproved overtime.
• Use simple analytics: average weekly hours by employee, frequency of late clock-outs, and travel time anomalies.

How to respond if you discover potential violations

If your internal audit uncovers unrecorded hours or overtime errors, act quickly:

• Stop the practice: immediately require accurate time recording and correct policies.
• Calculate exposure: determine total unpaid wages and estimated liquidated damages under the FLSA for the lookback period.
• Consult counsel: an employment lawyer experienced in wage-and-hour matters can advise on voluntary disclosures and mitigation strategies.
• Consider prompt remediation: paying back wages quickly and cooperating with any investigation may reduce litigation costs and reputational harm.

Note: each situation is unique. A legal advisor who understands healthcare operations, Medicaid/Medicare billing rules, and DOL enforcement practice is essential when you identify potential violations.

Special concerns for case managers and other mobile clinical staff

Case managers often perform tasks that are easily missed in timekeeping systems. Here are specific categories to capture and pay:

• Post-visit documentation: entering notes, scheduling follow-ups, or uploading records.
• Client travel: travel between client homes when driving during the workday.
• Required phone calls: calls to physicians, agencies, or family members that occur offsite.
• Mandatory training and meetings: whether online or in-person.
• On-call time: whether it is compensable time under FLSA depends on restrictions on the employee’s use of time.

What auditors look for — and how to prepare

DOL investigators reconstruct hours through payroll records, employee interviews, and contemporaneous logs. Typical red flags:

• Consistent rounding down of hours, or missing punch-outs after field shifts.
• Large numbers of employees reporting similar unrecorded tasks.
• Policies that require uncompensated administrative time.

Preparation steps:

• Create a complete, exportable record of timekeeping data going back at least two years where possible. Use modern systems that support an exportable audit trail.
• Maintain clear job descriptions and written policies demonstrating your compliance efforts.
• Document training and communications to staff about timekeeping requirements.

Price vs. prevention: budgeting for compliance in 2026

Small healthcare employers often view compliance as a cost center. But compare a modest budget for quarterly audits, a modern timekeeping app, and one or two training sessions to the true cost of a DOL judgment: six-figure back wages and liquidated damages, plus legal fees and lost public trust.

Budget checklist (annual):

• Timekeeping software subscription: modest monthly fee per user.
• Quarterly audit and HR consultant: plan for a few thousand dollars annually.
• Training and refresher materials: printed and digital resources for managers and staff.
• Legal retainer or access to counsel for classification and remediation advice.

For content creators and local publishers: how to cover these cases responsibly

If you write about wage violations, the public benefits from accurate, contextual reporting. Practical tips for journalists and community publishers:

• Verify court records and DOL press releases before publishing figures.
• Explain the root causes (off-the-clock work, recordkeeping gaps) so readers learn how to prevent similar harms.
• Provide local context: how state and local workforce patterns influence risk for small providers.
• Include actionable resources for employers and workers—eg., contact info for state labor offices, links to FLSA fact sheets.

Final checklist: immediate actions for small healthcare employers

• Run a 90-day timekeeping audit focused on mobile staff and case managers.
• Update timekeeping policies to explicitly include post-visit documentation and travel between clients.
• Deploy a mobile-friendly timekeeping system with timestamps and exportable audit trails.
• Train supervisors to approve time accurately and discourage off-the-clock work.
• Review classifications for exempt/nonexempt status with legal counsel.
• Schedule quarterly compliance checks and maintain records for potential audits.

Takeaways

The Wisconsin judgment is a practical warning: failing to pay for small, routine tasks can produce large financial exposure. For small healthcare employers — where staff are mobile, documentation burdens are high, and schedules vary — the solution is a combination of clear policies, reliable technology, and regular audits.

Implement the three fundamentals now: accurate recordkeeping, consistent payment for all work, and a workplace culture that encourages honest time reporting. Those measures will reduce the risk of back wages, mitigate legal exposure, and protect the mission-driven care your organization delivers.

Ready to act? Start with a single step this week: run a focused timekeeping audit for your case managers. If you find gaps, document them, fix policies, and consult counsel. Prevention is cheaper than cure — and quicker to restore trust with your team.

Call to action

Schedule a compliance review, download a timekeeping checklist, or connect with a wage-and-hour specialist. Protect your staff, protect your patients, and protect your organization from avoidable wage violations.

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