Remote work has become significantly more prevalent in recent years. What began as a necessity during the pandemic has evolved into a mainstream practice, with many organizations embracing hybrid or fully remote workforces to attract and retain talent. However, this trend also creates uncertainty for employers around wage-and-hour compliance, such as tracking hours worked and ensuring proper overtime compensation.
On September 4, 2025, the U.S. District Court for the Southern District of Ohio issued a significant opinion directly related to this topic. Lott v. Recker Consulting, LLC involves a Fair Labor Standards Act (FLSA) collective action brought by more than 130 remote Patient Care Associates (“PCAs”). Their employer required the remote PCAs to be in a “call-ready” state at the start of their shifts and at the end of their unpaid meal periods. However, getting to that call-ready state involved the PCAs first undertaking various preparatory activities, such as turning on their computer, logging in using a username and password, and opening various programs on their device. The PCAs also had to log back in after unpaid meal periods and were required to shut down their computers at the end of the workday. The issue before the court was whether these preliminary and postliminary activities constituted compensable work time.
The District Court succinctly presented the question of when the workday starts and ends for remote workers for purposes of compliance with the FLSA...
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