Are IDD and Medicaid Service Coordinators Exempt From Overtime?

Often no — a coordinator’s title does not decide the overtime question

Many salaried service coordinators and support coordinators in IDD, waiver and Medicaid programs spend their days on required contacts, plans and documentation. That kind of work frequently does not meet the federal tests for an exemption from overtime.

The three tests

An employer that calls you “exempt” generally has to prove all three:

  1. Salary basis. A fixed salary that does not drop when you work less. See salary versus hourly pay.
  2. Salary level. At least $684 per week, or $35,568 a year. The 2024 rule was vacated (E.D. Tex. Nov. 15, 2024), and the Labor Department formally reinstated the 2019 figures effective May 15, 2026.
  3. Duties. Your primary duty must fit one of the white-collar exemptions, usually the administrative or learned professional exemption.

Two different rules that get mixed up

You may have heard about the “companionship” or home care overtime rules. Those are about a different job.

The companionship exemption covers aides who provide “fellowship and protection for an elderly person or person with an illness, injury, or disability” who needs help caring for themselves (29 C.F.R. § 552.6). Since 2015, a third-party employer such as a home care agency “may not avail themselves of” that exemption (29 C.F.R. § 552.109). The Labor Department proposed changing that rule in 2025. Either way, the rule is about direct-care aides in the home.

Your status as a coordinator does not depend on it. A service coordinator who builds plans, makes required contacts and arranges services is judged under the ordinary white-collar tests: salary basis, salary level and duties.

The duties tests

Administrative (29 C.F.R. §§ 541.200–.203). The employer must show office work “directly related to the management or general business operations” of the employer and a primary duty that includes “the exercise of discretion and independent judgment” on matters of significance. The rules say that means more than “applying well-established techniques, procedures or specific standards described in manuals or other sources.” Coordinators usually work inside state waiver rules, program manuals, required contact schedules and plan templates. That is typically delivering the program, not running the business. See the administrative exemption.

Learned professional (29 C.F.R. §§ 541.300–.301). This requires a primary duty using “advanced knowledge in a field of science or learning customarily acquired by a prolonged course of specialized intellectual instruction.” Fact Sheet #17D limits it to professions where “specialized academic training is a standard prerequisite for entrance into the profession.” Many coordinator jobs accept a bachelor’s degree in any of several human-services fields, or experience in place of a degree. The regulation says the exemption does not reach jobs that can be done “with only the general knowledge acquired by an academic degree in any field.” A nursing or social work license helps an employer only if the job truly requires it and your main work uses it. See the learned professional exemption.

Usually points to non-exempt (overtime owed)

Can point toward exempt

Who this covers

Job titles vary by state and program: service coordinator, support coordinator, targeted case manager, waiver case manager, care coordinator, qualified intellectual disability professional (QIDP), and others. The title does not decide your status. The work does. Related pages: case managers, care coordinators, nonprofit case managers, social workers and child welfare caseworkers.

We have done this work before

We have brought overtime claims for salaried care coordinators, including Russell v. eQHealth Solutions, Inc. If your job sits in a waiver or managed care program and the employer calls everyone exempt, that is a pattern we know. See also managed care overtime and utilization review.

Prior results do not guarantee or predict a similar outcome in any future matter.

If you work in Texas

No Texas statute requires a private employer to pay overtime, so for a Texas service coordinator this is a federal claim under the FLSA. A colleague doing the same job in another state may also have a state wage claim with its own limitations period and damages. The federal remedy is the unpaid overtime premium plus an equal additional amount as liquidated damages, with the employer paying your attorney’s fees and costs if you prevail. The period reaches two years back from the date of filing, or three years if the violation was willful; see how far back an overtime claim reaches.

Common questions

I’m an IDD service coordinator, not a home care aide. Does the companionship rule apply to me?

No. That rule concerns aides who provide care in the home. A coordinator’s overtime status depends on salary and duties.

My employer says coordinators are professionals. Are they right?

Not necessarily. The professional exemption requires a job that truly needs a particular advanced degree. If the job accepts several kinds of degrees, or experience instead, that is a sign it does not.

I have a lot of responsibility for my clients. Doesn’t that make me exempt?

Responsibility and caring work are not the test. The question is whether your main job is running the employer’s business with real independent judgment, or carrying out a program under set rules.

I’m salaried and work for a nonprofit or a managed care company. Can I still be owed overtime?

Yes, if the exemption does not fit. Nonprofits are often covered by the overtime law. See nonprofit case managers.

Does the time I spend finishing notes at home count?

If your employer knows or has reason to know you are doing the work, that time generally counts as hours worked, wherever you do it.

Can I be fired for asking?

Federal law prohibits retaliation against employees who complain about unpaid wages or join an overtime claim.

Where to file a complaint with an agency

Sources

  1. 29 C.F.R. § 541.200(a) (the three elements of the administrative exemption); 29 C.F.R. § 541.202(a), (e) (discretion and independent judgment must be more than the use of skill in applying “well-established techniques, procedures or specific standards described in manuals or other sources”); 29 C.F.R. § 541.704 (use of manuals).
  2. 29 C.F.R. § 541.300(a); 29 C.F.R. § 541.301(a) (“advanced knowledge in a field of science or learning customarily acquired by a prolonged course of specialized intellectual instruction”).
  3. 29 C.F.R. § 541.301(d) (the exemption does not reach occupations that “customarily may be performed with only the general knowledge acquired by an academic degree in any field”); U.S. Dep’t of Labor, Wage & Hour Div., Fact Sheet #17D (“specialized academic training is a standard prerequisite for entrance into the profession”).
  4. 29 C.F.R. § 552.6 (companionship services: “fellowship and protection for an elderly person or person with an illness, injury, or disability” who requires assistance in caring for himself or herself).
  5. 29 C.F.R. § 552.109 (third-party employers “may not avail themselves of” the companionship services or live-in domestic service exemptions), effective 2015.
  6. 29 C.F.R. § 541.600(a) ($684 per week), as restored by 91 Fed. Reg. 27835 (May 15, 2026), after the 2024 salary-threshold rule was vacated (E.D. Tex. Nov. 15, 2024).
  7. 29 C.F.R. § 541.602(a) (salary basis: a “predetermined amount” that is “not subject to reduction because of variations in the quality or quantity of the work performed”).
  8. 29 C.F.R. § 541.2 (a job title does not determine exempt status); 29 C.F.R. § 541.700 (primary duty); 29 C.F.R. § 541.100(a)(3) (the executive exemption requires customarily and regularly directing the work of two or more other full-time employees).
  9. 29 C.F.R. § 785.11, § 785.12 (work the employer knows or has reason to believe is being performed is hours worked, including work done away from the premises).
  10. 29 U.S.C. § 207(a)(1) (overtime); 29 U.S.C. § 211(c) (employer recordkeeping); 29 U.S.C. § 215(a)(3) (retaliation); 29 U.S.C. § 216(b) (liquidated damages, fees and costs); 29 U.S.C. § 255(a) (two- and three-year periods).

Talk to us

We represent employees only. Jack Siegel has filed cases in 25 federal districts across 20 states and obtained 50+ class and collective certifications in 19 federal judicial districts across 14 states, as lead counsel on the firm’s cases. The firm has recovered more than $100 million for workers.

Prior results do not guarantee or predict a similar outcome in any future matter. These are results in other people’s cases. Each case is decided on its own facts, its own record and its own procedural posture. Conditional certification and class certification are procedural rulings about whether a case may proceed as a group action; they are not findings of liability and they are not an award of money. This website contains attorney advertising.

Salaried coordinator, called exempt, and working past 40 to keep up with contacts and plans? Send us your job posting and pay records for a free review. You pay no fee and no costs unless we recover. Call or text (214) 790-4454, email [email protected], or reach us through our contact page.

Attorney responsible: Jack L. Siegel, Dallas, Texas.

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