If you work in managed care — as a case manager, care coordinator, utilization review nurse, prior authorization specialist, or in any other care management role — there is a good chance you are owed overtime pay that your employer has never given you.
Managed care overtime misclassification is not an isolated problem at a handful of companies. It is a systemic, industry-wide pattern. Health plans, managed care organizations (MCOs), third-party administrators (TPAs), and behavioral health companies have been misclassifying thousands of care management workers as exempt from overtime for years — saving billions in labor costs while violating federal law.
The Fair Labor Standards Act (FLSA) requires overtime pay at one and one-half times your regular rate for every hour worked beyond 40 in a workweek. To avoid that requirement, your employer must prove that a specific exemption applies. Across the managed care industry, employers rely on the administrative exemption to deny overtime to case management workers. But the legal analysis is clear, and the Department of Labor has said so repeatedly: managed care case managers are not administrative employees under the FLSA.
Siegel Law Group has recovered more than $80 million for workers, filed cases against six Fortune 500 companies, and obtained more than 50 class and collective action certifications — many of them in managed care overtime lawsuits. This is the industry we know best, and these are the cases we were built to handle.
The key legal question in most managed care overtime cases is whether case management workers perform "production" work — the core service the employer exists to deliver — or "administrative" work that relates to running the business itself. Under 29 CFR § 541.200, only staff-level employees whose primary duties involve the management or general business operations of the employer can qualify for the administrative exemption.
This distinction is devastating for managed care companies, because case management is the core service product of a managed care organization. An MCO does not manufacture goods or sell retail products. Its entire business model revolves around managing the care of its members. When a health plan hires case managers, care coordinators, and utilization review nurses, those workers are delivering the very service the company sells to its clients — whether those clients are employers, state Medicaid agencies, or individual plan members.
That makes care management workers "production" employees under the FLSA. They perform the employer's core service function, not its business operations. The administrative exemption does not apply to them — no matter how much professional skill or judgment their work requires, and regardless of what the employer calls their job title.
The Department of Labor has directly addressed this question in multiple opinion letters, and the conclusion has been the same every time:
The DOL's Field Operations Handbook (FOH Section 22j49(a)) also directs federal investigators to treat case managers as generally non-exempt. These are not academic footnotes — they represent the enforcement position of the federal agency responsible for the FLSA. When the government itself says managed care case managers should receive overtime, employers claiming otherwise face an uphill battle.
Under 29 CFR § 541.202, the administrative exemption also requires that an employee exercise "discretion and independent judgment with respect to matters of significance." MCOs routinely argue that because case managers and care coordinators make day-to-day decisions about care plans and service authorizations, they satisfy this test.
They do not. There is a fundamental difference between applying established clinical protocols — which is what managed care workers do — and making high-level business decisions that affect the direction of the company. Case managers work within standardized assessment tools, evidence-based treatment guidelines, medical necessity criteria, and internal policies set by the employer. The FLSA regulations are explicit: applying well-established techniques, procedures, or specific standards does not constitute the type of discretion required for exemption, even when the work involves professional skill.
Managed care overtime violations are not confined to one type of company. The misclassification pattern cuts across the entire industry. If you work for any of the following types of employers, you should evaluate whether you are being properly paid for overtime.
The largest health insurers in the country employ thousands of case management workers — and many of them classify those workers as exempt from overtime. These are companies with enormous financial incentives to avoid paying time-and-a-half: every unpaid overtime hour across a workforce of several thousand case managers translates directly into millions of dollars in savings.
Major health insurance companies that employ large numbers of case management workers include:
Siegel Law Group has filed managed care overtime lawsuits against multiple companies on this list. We have gone head-to-head with some of the wealthiest corporations in America — and won.
State Medicaid programs across the country have shifted to managed care delivery models, contracting with MCOs to administer benefits for millions of low-income individuals. These Medicaid MCOs employ large numbers of case managers, care coordinators, and service coordinators to manage member populations with complex health needs. Many of these plans — whether national carriers operating state contracts or regional plans — misclassify their case management workforce.
Companies that manage behavioral health benefits — including mental health, substance use disorder treatment, and employee assistance programs — employ care coordinators and case managers who face the same misclassification problems. Companies such as Magellan Health, Beacon Health Options, and other behavioral health carve-outs have been the subject of overtime litigation. Siegel Law Group's $16 million settlement in Deakin v. Magellan Health, which achieved both class certification and summary judgment, arose from exactly this type of violation.
PBMs and TPAs play a growing role in managed care, employing prior authorization specialists, utilization review staff, and case management professionals who process claims, review medical necessity, and coordinate care on behalf of health plans. These workers frequently work more than 40 hours per week and are improperly classified as exempt.
Managed care companies use a wide variety of job titles for workers who perform substantially similar case management duties. Regardless of title, if your primary duties involve coordinating and managing care for plan members, the FLSA overtime analysis is likely the same. Commonly affected roles include:
If your role involves coordinating care, managing cases, reviewing utilization, or authorizing services for a managed care company, your job likely qualifies for overtime protection — regardless of what your employer calls your position.
Federal courts across the country have recognized that managed care workers are entitled to overtime. Siegel Law Group has been at the center of many of the largest managed care overtime cases ever litigated.
This hybrid FLSA collective action and state-law class action was brought on behalf of managed care workers at Presbyterian Healthcare Services, New Mexico's largest private employer. The $38.7 million settlement — pending final approval — is one of the largest managed care overtime recoveries in the history of FLSA litigation. The case demonstrates the enormous collective action potential when a major health plan misclassifies its entire case management workforce.
This case was brought on behalf of approximately 200 Care Coordinators at Magellan Health, one of the nation's largest behavioral health managed care companies. After eight years of litigation, the case achieved both class certification and summary judgment on the misclassification issue before settling for $16 million. The court's summary judgment ruling — finding that Magellan's care coordinators were misclassified as a matter of law — is a powerful precedent for managed care overtime cases.
This case involved case management workers at Unum Group, the third-largest group disability carrier in the United States and a Fortune 500 company. The $14.8 million settlement — with 947 class members — further demonstrates that even the largest and most well-resourced companies in the industry cannot defend their misclassification practices when the legal analysis is applied.
The pattern extends well beyond these three cases. Siegel Law Group has obtained certifications and recoveries in managed care overtime actions involving thousands of workers:
These results reflect more than a decade of concentrated litigation against managed care companies. No firm in the country has more experience in this specific area of FLSA law.
There are several reasons managed care produces more overtime violations than almost any other industry.
Massive workforces in a single job category. A single large MCO may employ 500, 2,000, or even 5,000 or more case management workers. When an employer applies the same misclassification policy across that entire workforce, the result is a collective or class action with enormous potential. The damages multiply with every worker and every unpaid hour.
Financial incentives to misclassify. Managed care is a cost-driven business. MCOs generate revenue by managing healthcare costs below the premiums they collect. Every dollar saved on labor — including every hour of unpaid overtime — flows to the bottom line. The financial incentive to classify case management workers as exempt is powerful and pervasive.
Industry-wide copycat practices. Managed care companies benchmark their HR and compensation practices against each other. When one major MCO classifies its case managers as exempt, competitors often follow suit — creating an industry-wide norm that is legally wrong but economically convenient.
High overtime hours as a structural feature. Managed care workers routinely report working 45, 50, or even 60 hours per week. The nature of the work — managing complex patient populations, responding to time-sensitive authorization requests, completing documentation, and coordinating across providers — makes overtime a built-in feature of the job, not an occasional occurrence. Many workers also perform significant off-the-clock work, answering calls and emails outside of scheduled hours or completing charting at home.
Rapid industry growth. The managed care industry continues to expand as more states shift Medicaid populations into managed care, Medicare Advantage enrollment grows, and value-based care models increase the demand for care coordination. This growth means more workers are being hired into misclassified positions every year.
Managed care overtime cases are typically brought as FLSA collective actions under 29 U.S.C. Section 216(b), often combined with state-law class actions under Rule 23. This hybrid approach allows workers to recover both federal FLSA overtime and state overtime or wage law damages — maximizing the recovery for every class member.
In an FLSA collective action, one or more named plaintiffs file a lawsuit alleging that their employer misclassified a group of workers. The court then decides whether to conditionally certify the case — meaning other workers who held similar positions can opt in to the lawsuit and share in any recovery. In managed care cases, conditional certification rates are high because the misclassification is typically applied uniformly: every case manager or care coordinator at the company is classified the same way, performs the same core duties, and is subject to the same overtime policy.
Siegel Law Group has obtained more than 50 collective and class action certifications. We understand how these cases are built, certified, and resolved.
If your employer has misclassified you, you may be entitled to:
For a managed care worker earning $65,000 to $85,000 per year and working five to ten hours of unpaid overtime per week, individual damages can range from $15,000 to $60,000 or more — before liquidated damages. Across a class of hundreds or thousands of workers, total damages regularly reach into the tens of millions of dollars.
Federal law prohibits your employer from retaliating against you for exercising your rights under the FLSA. Your employer cannot fire you, demote you, reduce your hours, change your schedule, or take any other adverse action against you because you participated in an overtime lawsuit or inquired about your overtime rights. The FLSA's anti-retaliation provision, 29 U.S.C. Section 215(a)(3), provides its own cause of action for workers who experience retaliation.
In our experience, the fear of retaliation is far more common than actual retaliation — particularly in large managed care companies where HR and legal departments understand the legal risk of retaliating against a plaintiff in a federal lawsuit.
If you work in managed care and you are not receiving overtime pay for hours worked beyond 40 per week, you should talk to someone who handles these cases every day. Siegel Law Group has recovered more than $80 million for workers, filed cases against six Fortune 500 companies, and litigated managed care overtime cases for more than a decade. This is what we do.
Initial consultations are free and typically take only 5 to 10 minutes. We will ask about your job title, your duties, how you are paid, and how many hours you typically work. That is usually enough for us to tell you whether you have a case.
Contact Siegel Law Group to discuss your managed care overtime claim. You can reach us by text or phone at (214) 790-4454 or by email at [email protected]. Text is the fastest way to reach us.
Prior results do not guarantee a similar outcome. No representation is made that the quality of legal services to be performed is greater than the quality of legal services performed by other lawyers.
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