A federal court has ordered a Wisconsin-based multicounty medical care partnership to pay $162,486 in back wages and liquidated damages to 68 case managers after a US Department of Labor (DOL) investigation found the employer failed to pay all wages owed for off-the-clock work, including overtime. The DOL announced the judgment on January 15, 2026.
Entered in the US District Court for the Western District of Wisconsin, the consent judgment follows an investigation by the department’s Wage and Hour Division which found that case managers employed by the company worked unrecorded hours.
The department’s complaint alleged that between June 17, 2021, and June 16, 2023, the company violated overtime and recordkeeping provisions of the Fair Labor Standards Act (FLSA) by failing to record and pay case managers for all hours worked, including overtime. 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. Employers are also required to record all compensable time worked each day, including time worked in small increments, to determine an employee’s regular rate of pay.
Entered on Dec. 4, 2025, the judgment requires the company to pay $81,243 in back wages and an equal amount in liquidated damages to the 68 employees. The employer is also enjoined from future FLSA violations.
Compliance Perspective
Issue
The FLSA establishes minimum wage, overtime pay, and recordkeeping requirements for most employers. Unless exempt, covered employees must be paid at least the federal minimum wage and at least one and one-half times their regular rate of pay for all hours worked over 40 in a workweek. Hours worked generally include all time an employee is required to be on duty, on the employer’s premises, or performing work-related activities, whether scheduled or unscheduled. Employers are also required to maintain accurate and complete records of hours worked and wages paid for each non-exempt employee. Failure to maintain compliant wage and hour practices and accurate records can result in enforcement actions and financial liability.
Discussion Points
- Review policies and procedures related to timekeeping, overtime eligibility, and recordkeeping to ensure alignment with federal and applicable state requirements. Policies should clearly define what constitutes compensable time, how overtime is calculated, and employee and supervisor responsibilities for accurately recording hours worked. As part of this review process, some organizations find it beneficial to engage an external consultant to assess existing practices, identify gaps, and provide objective feedback aligned with regulatory expectations and industry standards.
- Provide training for staff responsible for determining fair wages, overtime pay eligibility, and recordkeeping. Med-Net Academy offers the course Employee Recordkeeping Requirements and Education, which focuses on the documentation that must be maintained in employee files, including in-service training records, licensure verification, and competency documentation. The course emphasizes how proper recordkeeping supports regulatory compliance, demonstrates staff competency, and ensures required documentation is complete, organized, and readily available for review. An additional course titled Guidelines for Rest and Meal Periods addresses DOL expectations for provision of rest and meal breaks for staff in order to comply with the Code of Federal Regulations, Title 29. It presents multiple related case study examples.
- Conduct routine audits of wage and hour practices to verify that all compensable time is captured, overtime is properly calculated, and records are complete and accurate. Audit activities may include reviewing timekeeping systems and payroll records to ensure that all compensable hours are accurately recorded and paid. Periodic reviews conducted by an external consultant can provide an objective assessment of compliance, help identify potential risks early, and support timely corrective action.
*This news alert has been prepared by Med-Net Concepts, Inc. for informational purposes only and is not intended to provide legal advice.*