Managed Care Has an Overtime Problem

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.

This isn't limited to a handful of companies. Health plans, managed care organizations (MCOs), third-party administrators (TPAs) and behavioral health companies have classified care management staff as exempt for years. We've sued many of them, and the list is below.

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 settled overtime claims for more than 1,400 salaried managed care employees. Our practice concentrates in this industry. The cases we’ve brought are listed below.

Why Managed Care Workers Are Entitled to Overtime

The "Production vs. Staff" Analysis

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 matters 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.

DOL Has Consistently Sided with Managed Care Workers

The Department of Labor has directly addressed this question in multiple opinion letters, and the conclusion has been the same every time:

• DOL Opinion Letter FLSA2005-25 (August 2005) — Reviewed insurance company case managers and found them non-exempt. Even though these workers assessed claims and coordinated care, they were performing the insurance company's core business function.
• DOL Opinion Letter FLSA2006-37 (September 2006) — Reinforced that case management duties are production work, not administrative work under the FLSA.
• DOL Opinion Letter FLSA2007-7 (February 2007) — Examined case managers at a disability services provider and concluded they were non-exempt. Their primary duties were the core services their employer existed to deliver.

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.

Discretion and Independent Judgment: Not What Employers Claim

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.

Types of Managed Care Employers That Misclassify Workers

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.

Health Insurance Companies and National MCOs

The largest health insurers in the country employ thousands of case management workers — and many of them classify those workers as exempt from overtime. Every unpaid overtime hour across a workforce of several thousand case managers adds up.

Major health insurance companies that employ large numbers of case management workers include:

• UnitedHealth Group / UnitedHealthcare / Optum — a national health insurer
• CVS Health / Aetna / Caremark — a pharmacy and managed care company
• Centene Corporation — a Medicaid managed care company whose subsidiaries include Meridian Health Plan, IlliniCare Health Plan, Buckeye Health Plan and WellCare
• Elevance Health (Anthem / Blue Cross Blue Shield) — a national managed care company
• Humana — Major national health plan with substantial Medicare Advantage operations
• Molina Healthcare — a major Medicaid and Medicare managed care company
• HCSC (Health Care Service Corporation) — a customer-owned health insurer operating Blue Cross Blue Shield plans in five states

Siegel Law Group has filed managed care overtime lawsuits against several companies on this list. The cases are listed below.

Medicaid Managed Care Plans

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.

Behavioral Health MCOs

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 Beacon Health Options and other behavioral health carve-outs have been the subject of overtime litigation.

Pharmacy Benefit Managers (PBMs) and Third-Party Administrators

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.

Roles Affected by Managed Care Overtime Violations

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:

• Case Managers — The most commonly misclassified position in managed care. Case managers assess member needs, develop care plans, coordinate services, and monitor outcomes. Whether your title is "RN Case Manager," "Medical Case Manager," or "Complex Case Manager," the analysis is the same.
• Care Coordinators — Often used interchangeably with "case manager," care coordinators perform the same core production functions: assessing needs, coordinating services, and ensuring members receive appropriate care.
• Utilization Review Nurses — UR nurses review treatment requests against medical necessity criteria, process prior authorizations, and make coverage determinations. These functions are core to the managed care business model.
• Prior Authorization Specialists — Workers who process prior authorization requests, apply clinical criteria to treatment requests, and coordinate with providers on coverage decisions.
• Disease Management Nurses — Nurses who manage populations of members with chronic conditions such as diabetes, heart failure, COPD, or behavioral health diagnoses.
• Care Management Specialists — A catch-all title used by many MCOs for workers who perform care coordination, transition planning, and member outreach functions.
• Service Coordinators — Common in Medicaid managed care, service coordinators connect members with community resources, manage referrals, and track service delivery.

Courts have conditionally certified collectives across these roles, including utilization review nurses, case managers, care advisors, and care coordinators at Evolent Health in four states, Utilization Managers at New Directions Behavioral Health, UM nurses at Concerto Healthcare, and Disability Benefits Specialists at Unum.

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.

Cases we've brought

Siegel Law Group has settled overtime claims for more than 1,400 salaried managed care employees.¹ Below are the federal cases we've brought against health plans and managed care companies, grouped by employer family. Where a company has changed its name or owner, the newer name is shown. Our New Mexico cases have their own page: New Mexico managed care cases →, and that state's overtime law is explained on our New Mexico wage law page. To check a specific employer, see employers we’ve taken to court.

Presbyterian Health Plan (New Mexico)

• Pruess v. Presbyterian Health Plan, Inc., No. 1:19-cv-00629 (D.N.M.). On June 24, 2026, Judge David H. Urias granted final approval of a $38.7 million settlement for 918 care coordinators and UM nurses (Doc. 331).² Read about the settlement

UnitedHealth Group family (UnitedHealthcare, NaviHealth)

Ownership: NaviHealth is an Optum company.

• Barbee v. NaviHealth, Inc., No. 3:19-cv-00119 (M.D. Tenn.). Settled the overtime claims of more than 1,100 salaried employees on an FLSA collective and Rule 23 basis. The court approved Jack Siegel as class counsel.³ Read about the settlement
• Fedor v. United Healthcare, Inc. (D.N.M.; 10th Cir.). Two Tenth Circuit rulings (2020, published; 2022, unpublished) rejected UnitedHealthcare's attempt to force care coordinators into arbitration.⁴ 2020 ruling · 2022 ruling

Aetna (CVS Health)

• Winston v. Aetna Life Insurance Co., No. 2:19-cv-04703 (D. Ariz.). Conditionally certified as a collective action. Notice went to more than 550 salaried managed care employees, and the claims of all opt-ins settled.⁵

Molina Healthcare

• Gongora-Ownby v. Molina Healthcare, Inc., No. 1:16-cv-11346 (N.D. Ill.), and Brewer v. Molina Healthcare, Inc., No. 1:16-cv-09523 (N.D. Ill.). Resolved together in one settlement covering the overtime claims of more than 1,100 salaried Case Managers and Health Managers.⁶ Gongora-Ownby settlement · Brewer settlement

Sentara Health Plans

Also called: Optima Health Plan, renamed Sentara Health Plans.⁷

• Brunty v. Optima Health Plan, No. 2:19-cv-00255 (E.D. Va.). Settled the overtime claims of 178 managed care employees on a class-wide basis.⁷ Read the ruling · Read about the settlement
• Edwards v. Optima Health Plan, No. 2:20-cv-00192 (E.D. Va.). Won conditional certification and settled the claims of more than 100 salaried care management employees.⁷ Read the ruling

Gateway Health Plan

• Jones v. Gateway Health Plan, Inc. (W.D. Pa.). A collective of salaried care management employees was conditionally certified, and the claims of all opt-ins settled.⁸

Carelon Behavioral Health

Also called: Beacon Health Options, renamed Carelon Behavioral Health in 2023.⁹

• Pettenato v. Beacon Health Options, Inc., No. 1:19-cv-01646 (S.D.N.Y.). Conditionally certified as a collective action. The overtime claims of 43 salaried managed care employees settled.⁹ Read the ruling

Evolent Health, eQHealth Solutions and New Directions Behavioral Health

• Kelly v. Evolent Health LLC, No. 1:19-cv-00500 (N.D. Ill.). Settled the claims of about 69 opt-ins, including workers who reviewed medical claims for medical necessity.¹⁰ Read the ruling · Read about the settlement
• Russell v. eQHealth Solutions, Inc., No. 3:19-cv-00005 (M.D. La.). Settled the claims of 63 workers classified as exempt who reviewed medical claims against medical-necessity criteria.¹⁰ Read the ruling · Read about the settlement
• Krott v. New Directions Behavioral Health, L.L.C., No. 4:19-cv-00915 (W.D. Mo.). Settled the claims of 31 workers classified as exempt who reviewed medical claims for medical necessity.¹⁰ Read the ruling · Read about the settlement

Vaya Health

Also called: Cardinal Innovations Healthcare, which consolidated with Vaya Health in 2021.¹¹

• Kirkpatrick v. Cardinal Innovations Healthcare Solutions, No. 1:16-cv-01088 (M.D.N.C.). On September 1, 2017, the court conditionally certified a collective of I/DD Care Coordinators and denied Cardinal's motion to strike the consent forms of workers who had already joined.¹¹ Read the ruling

Regional health plans and utilization review companies

• Drake v. Tufts Associated Health Maintenance Organization, Inc., No. 1:19-cv-11876 (D. Mass.). On February 12, 2021, the court conditionally certified a collective of utilization review employees over the health plans’ opposition. The case later settled.¹² Read the ruling · Read about the settlement
• Gardner v. Fallon Health & Life Assurance Co., No. 4:19-cv-40148 (D. Mass.). On September 29, 2021, the court conditionally certified a collective of salaried UM nurses.¹² Read the ruling
• Bellan v. Capital BlueCross, No. 1:20-cv-00744 (M.D. Pa.). On October 26, 2020, the court conditionally certified a collective of non-management utilization review employees. The case later settled.¹² Read the ruling · Read about the settlement
• Snider v. Quantum Health, Inc., No. 2:20-cv-02296 (S.D. Ohio). On February 1, 2021, the court conditionally certified a collective of salaried utilization review employees in Ohio. The case later settled.¹² Read the ruling · Read about the settlement
• Menth v. Concerto Healthcare, Inc., No. 2:20-cv-11514 (E.D. Mich.). On October 2, 2020, the court entered a stipulated order conditionally certifying a collective of salaried workers who did utilization review.¹² Read the ruling

Centene family

Ownership: Superior HealthPlan and IlliniCare Health Plan are Centene plans. Caidan Management Company (Meridian) was acquired by WellCare in 2018, and WellCare by Centene in 2020.¹³

• Del Toro v. Centene Management Co., No. 4:19-cv-02635 (E.D. Mo.). A hybrid case with federal and state overtime claims and multiple Rule 23 classes. Settled the claims of 1,228 salaried employees on a class-wide basis.¹⁴ Read the ruling · Read about the settlement
• Jackson v. Superior HealthPlan, Inc., No. 3:15-cv-03125 (N.D. Tex.). On November 7, 2016, the court conditionally certified a collective of Field Service Coordinators.¹⁴ Read the ruling
• Linnear v. IlliniCare Health Plan, Inc., No. 1:17-cv-07132 (N.D. Ill.). Settled the overtime claims of 545 care coordinators, Program Specialists and Behavioral Case Managers. The court approved Jack Siegel as class counsel.¹⁴ Read about the settlement
• Slaughter v. Caidan Management Co., No. 1:17-cv-05846 (N.D. Ill.). On July 5, 2018, the court conditionally certified a collective of salaried care management employees in Michigan and Illinois. The case later settled for about 845 Care Management Employees.¹⁴ Read the ruling · Read about the settlement

Disability insurer cases (Unum, Matrix Absence Management, Reliance Standard) are on our claims examiners page.

These are results in other people's cases. Every case depends on its own facts and law. Prior results do not guarantee a similar outcome.

Why Managed Care Produces So Many Overtime Cases

Several features of the industry make misclassification common.

Large 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 that can cover many workers. 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. That creates an incentive to classify case management workers as exempt.

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 norm that doesn't fit the law.

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.

How Managed Care Overtime Lawsuits Work

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.

The Collective Action Process

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 is often granted 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 50+ collective and class action certifications. We understand how these cases are built, certified, and resolved.

What You Can Recover

If your employer has misclassified you, you may be entitled to:

• Back overtime pay — Time-and-a-half for every hour worked over 40 in each workweek, going back two years (or three years if the violation was willful)
• Liquidated damages — An additional amount equal to your unpaid overtime, effectively doubling your recovery under the FLSA
• State-law damages — Many state wage laws provide additional penalties, longer lookback periods, or treble damages that exceed what the FLSA alone allows
• Attorneys' fees and costs — Paid by the employer, not deducted from your recovery

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 can reach into the millions of dollars.

You Are Protected from Retaliation

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.

Talk to a Managed Care Overtime Lawyer

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 filed cases against UnitedHealthcare (a UnitedHealth Group company), Caremark PHC, LLC (CVS Caremark), Molina Healthcare and Unum Group, and litigated managed care overtime cases for more than a decade.

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.

These are results in other people's cases. Every case depends on its own facts and law. 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.

Attorney responsible: Jack L. Siegel, Siegel Law Group PLLC, Dallas, Texas.

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Notes

1. Declaration of Jack L. Siegel ¶ 5, Heckle v. Matrix Absence Mgmt., Inc., No. 7:21-cv-01463 (S.D.N.Y. Mar. 21, 2022) (subparagraphs (b) Barbee, more than 1,100; (c) Brunty, 178; (f) Pettenato, 43; (l) Edwards, more than 100); Declaration of Jack Siegel ¶ 13, filed in Weeks v. Matrix Absence Mgmt., No. 2:20-cv-00884 (D. Ariz. July 6, 2022) (subparagraph (c): Russell, 63). Total 1,484.
2. Pruess v. Presbyterian Health Plan, Inc., No. 1:19-cv-00629 (D.N.M. June 24, 2026) (order granting final approval), Doc. 331.
3. Declaration of Jack L. Siegel ¶ 5, Heckle v. Matrix Absence Mgmt., Inc., No. 7:21-cv-01463 (S.D.N.Y. Mar. 21, 2022) (b); Declaration of Jack Siegel ¶ 13, filed in Weeks v. Matrix Absence Mgmt., No. 2:20-cv-00884 (D. Ariz. July 6, 2022) (d) (class counsel); docket.
4. Fedor v. United Healthcare, Inc., 976 F.3d 1100 (10th Cir. 2020); Fedor v. United Healthcare, Inc., No. 21-2051 (10th Cir. Apr. 11, 2022) (unpublished).
5. Declaration of Jack L. Siegel ¶ 5, Heckle v. Matrix Absence Mgmt., Inc., No. 7:21-cv-01463 (S.D.N.Y. Mar. 21, 2022) (e).
6. Dockets: Gongora-Ownby, No. 1:16-cv-11346 (N.D. Ill.); Brewer, No. 1:16-cv-09523 (N.D. Ill.).
7. Declaration of Jack L. Siegel ¶ 5, Heckle v. Matrix Absence Mgmt., Inc., No. 7:21-cv-01463 (S.D.N.Y. Mar. 21, 2022) (c) (Brunty), (l) (Edwards). Name change: Sentara Health Plans, “Optima Health is now Sentara Health Plans”.
8. Declaration of Jack L. Siegel ¶ 5, Heckle v. Matrix Absence Mgmt., Inc., No. 7:21-cv-01463 (S.D.N.Y. Mar. 21, 2022) (j); docket.
9. Declaration of Jack L. Siegel ¶ 5, Heckle v. Matrix Absence Mgmt., Inc., No. 7:21-cv-01463 (S.D.N.Y. Mar. 21, 2022) (f). Name change: “Beacon Health Options is now Carelon Behavioral Health” (June 5, 2023).
10. Declaration of Jack Siegel ¶ 13, filed in Weeks v. Matrix Absence Mgmt., No. 2:20-cv-00884 (D. Ariz. July 6, 2022) (c); dockets: Kelly, Russell.
11. Kirkpatrick v. Cardinal Innovations Healthcare Sols., No. 1:16-cv-1088 (M.D.N.C. Sept. 1, 2017) (memorandum opinion and order granting conditional certification). Consolidation: “Vaya Health and Cardinal Innovations Announce Consolidation” (June 2021).
12. Drake, No. 19-11876-FDS (D. Mass. Feb. 12, 2021) (memorandum and order); Gardner, No. 4:19-cv-40148 (D. Mass. Sept. 29, 2021); Bellan, No. 1:20-cv-00744 (M.D. Pa. Oct. 26, 2020); Snider, No. 2:20-cv-02296 (S.D. Ohio Feb. 1, 2021) (opinion and order); Menth, No. 2:20-cv-11514 (E.D. Mich. Oct. 2, 2020) (stipulated order).
13. WellCare Health Plans, Inc., Form 8-K (Sept. 2018) (acquisition of Caidan Management Company, LLC effective Sept. 1, 2018); “Centene Completes Acquisition of WellCare” (Jan. 2020).
14. Declaration of Jack L. Siegel ¶ 5, Heckle v. Matrix Absence Mgmt., Inc., No. 7:21-cv-01463 (S.D.N.Y. Mar. 21, 2022) (a) (Del Toro); docket. Declaration of Jack Siegel ¶ 13, filed in Weeks v. Matrix Absence Mgmt., No. 2:20-cv-00884 (D. Ariz. July 6, 2022) (b) (Jackson), (d) (Linnear class counsel). Jackson, No. 3:15-cv-3125-L (N.D. Tex. Nov. 7, 2016); Slaughter, No. 1:17-cv-05846 (N.D. Ill. July 5, 2018).