{
    "schema": "amendsignal.record/1",
    "generated_on": "2026-11-04",
    "publisher": {
        "name": "AmendSignal",
        "url": "https://amendsignal.com/"
    },
    "notice": "Coverage is limited, so a missing record does not mean nothing changed. General information, not legal advice. Check the official source. Please cite the record's url.",
    "change": {
        "id": 63,
        "url": "https://amendsignal.com/changes/wage-and-hour-division-opinion-letter-addresses-hospital-pre-shift-work-waiting-time-de-minimis-time/",
        "title": "Wage and Hour Division opinion letter addresses hospital pre-shift work, waiting time, de minimis time and rounding",
        "change_type": "guidance",
        "change_type_label": "Opinion letter",
        "status": "guidance_issued",
        "status_label": "Issued as agency guidance",
        "status_statement": "As of our last check on November 2, 2026, this is agency guidance, not a rule. It explains how the agency reads the law and does not create a legal requirement on its own.",
        "significance": "No new requirements",
        "jurisdiction": {
            "code": "US",
            "name": "United States"
        },
        "authority": {
            "name": "Wage and Hour Division",
            "short_name": "WHD"
        },
        "identifiers": [
            {
                "type": "opinion_letter_number",
                "label": "Opinion letter",
                "value": "FLSA2026-8"
            }
        ],
        "dates": [
            {
                "type": "publication",
                "label": "Published",
                "value": "2026-05-28",
                "precision": "day"
            }
        ],
        "in_short": {
            "what_changed": "The Department of Labor's Wage and Hour Division (WHD) issued an opinion letter applying the Fair Labor Standards Act (FLSA) to a hospital's pre-shift work, clock-in waiting time, de minimis claims and time rounding.",
            "whos_affected": "The letter answers one employee of a public hospital, but its reasoning is relevant to any employer covered by the FLSA whose non-exempt employees clock in early or whose time is rounded.",
            "what_to_do": "This opinion letter creates no new legal requirement. Employers that round early clock-ins to the shift start, let workers begin tasks before their paid shift, or treat short pre-shift periods as de minimis may want to review those practices against WHD's reasoning."
        },
        "summary": "The Department of Labor's Wage and Hour Division (WHD) issued opinion letter FLSA2026-8 on a public hospital's timekeeping and pay practices under the Fair Labor Standards Act (FLSA). WHD says some pre-shift tasks, such as receiving patient handoff reports, are compensable work. It says waiting in line to clock in or out before or after the workday is not. It also says rounding only early clock-ins to the shift start is not neutral if employees do compensable work in that time. The letter is guidance based on one requester's facts and creates no new legal requirement.",
        "business_functions": {
            "state": "limited",
            "functions": [
                {
                    "slug": "human-resources",
                    "name": "Human resources"
                },
                {
                    "slug": "payroll",
                    "name": "Payroll"
                },
                {
                    "slug": "legal-and-compliance",
                    "name": "Legal and compliance"
                },
                {
                    "slug": "technology",
                    "name": "Technology"
                }
            ]
        },
        "added_on": "2026-11-03",
        "updated_on": null,
        "updates_in_progress": null,
        "last_checked": "2026-11-02",
        "record_url": "https://amendsignal.com/changes/wage-and-hour-division-opinion-letter-addresses-hospital-pre-shift-work-waiting-time-de-minimis-time/record.json",
        "what_changed": [
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "WHD says at least some pre-shift tasks the hospital's employees perform after clocking in are compensable hours worked because they are integral and indispensable to their jobs. Examples are respiratory therapists receiving patient handoff reports and locating their work assignments.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, A. Compensability of Pre-Shift Activities and Time Spent Waiting at Timekeeping Stations",
                        "excerpt": "at least some of these activities appear to be integral and indispensable to the employees’ principal job duties, and are therefore compensable hours worked."
                    },
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, A. Compensability of Pre-Shift Activities and Time Spent Waiting at Timekeeping Stations",
                        "excerpt": "receiving handoff reports regarding patient status is essential because a respiratory therapist cannot safely begin patient care without understanding each patient’s current medical condition"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "WHD says time spent waiting in line to clock in and out is not compensable when it happens before the first or after the last principal activity of the workday. Waiting time during the workday is treated differently.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, A. Compensability of Pre-Shift Activities and Time Spent Waiting at Timekeeping Stations",
                        "excerpt": "On the other hand, time spent waiting in line to clock in and out is not compensable."
                    },
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Footnote 2",
                        "excerpt": "This general principle applies only to time before or after the workday"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "WHD says compensable work done every day before the paid shift is unlikely to be de minimis, but it could not conclude whether the hospital's pre-shift time is or is not de minimis on the facts given.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, B. Applicability of the De Minimis Doctrine",
                        "excerpt": "To the extent that each day, employees are performing compensable work prior to their paid shifts commencing, such work is unlikely to be de minimis."
                    },
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, B. Applicability of the De Minimis Doctrine",
                        "excerpt": "we are unable to conclude that the time is—or is not—de minimis."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "WHD says that if employees do compensable work before their shift, rounding early clock-ins up to the scheduled start is neither facially neutral nor neutrally applied, and is inconsistent with the Department of Labor's rounding regulation in the Code of Federal Regulations (CFR) at 29 CFR 785.48(b).",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Introduction",
                        "excerpt": "If employees are in fact performing compensable work before their scheduled shift begins, the employer’s rounding practice at the beginning of the day is neither facially neutral nor neutrally applied"
                    },
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, C. Rounding Policy Compliance with 29 C.F.R. § 785.48(b)",
                        "excerpt": "the hospital’s rounding practice is inconsistent with section 785.48(b) and would result in a failure to properly record, as well as potentially to properly compensate for, all hours worked."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "WHD says a rounding policy would likely comply if employees also benefit from it, for example if late clock-ins of up to 7 minutes are credited at the scheduled start and this averages out over time.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, C. Rounding Policy Compliance with 29 C.F.R. § 785.48(b)",
                        "excerpt": "if employees who clock in up to 7 minutes late are nonetheless credited with starting at their scheduled time and that practice averages out over time to offset any work time lost due to the rounding of early check-ins to the scheduled shift time—then the policy would likely comply with section 785.48(b)."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "WHD found no basis to treat the hospital's ban on early clock-outs as non-neutral rounding, because nothing showed employees work after their paid shift ends.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, C. Rounding Policy Compliance with 29 C.F.R. § 785.48(b)",
                        "excerpt": "we have no basis on which to conclude that your employer’s prohibition of early clock-outs constitutes non-neutral rounding under section 785.48"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "The letter is an official interpretation that may be relied on under section 10 of the Portal-to-Portal Act.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Closing",
                        "excerpt": "This interpretation may be relied upon in accordance with section 10 of the Portal-to-Portal Act"
                    }
                ]
            }
        ],
        "who_is_affected": [
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "The request came from a non-exempt employee of a public hospital with about 18,000 non-exempt employees.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Background",
                        "excerpt": "You represent that you are a non-exempt employee of a public hospital that employs approximately 18,000 non-exempt employees."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "The opinion is based only on the facts the requester described, and WHD says other facts might lead to a different conclusion.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Note following signature",
                        "excerpt": "This opinion is based exclusively on the facts and circumstances described in your request"
                    },
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Note following signature",
                        "excerpt": "The existence of any other factual or historical background not contained in your letter might require a conclusion different from the one expressed herein."
                    }
                ]
            },
            {
                "kind": "inference",
                "kind_label": "Our analysis",
                "text": "Although the letter answers one hospital's facts, WHD addresses some of its cautions to employers generally, so its reasoning is relevant to any covered employer with non-exempt employees who clock in early or whose time is rounded.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, B. Applicability of the De Minimis Doctrine",
                        "excerpt": "Employers, including the hospital at issue here, should nonetheless be particularly careful about how and to what extent they apply the de minimis doctrine."
                    },
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "General Legal Principles, A. The Fair Labor Standards Act",
                        "excerpt": "The FLSA requires covered employers to pay all non-exempt employees at least the federal minimum wage for all hours worked."
                    }
                ]
            }
        ],
        "business_implications": [
            {
                "kind": "inference",
                "kind_label": "Our analysis",
                "text": "Employers that round only early clock-ins to the shift start, with no offsetting rounding in the employee's favor, may face minimum wage or overtime exposure if employees start work before the paid shift.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Introduction",
                        "excerpt": "If employees are in fact performing compensable work before their scheduled shift begins, the employer’s rounding practice at the beginning of the day is neither facially neutral nor neutrally applied"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "WHD says employers should expect exacting scrutiny of de minimis claims where off-the-clock work happens with any regularity, given modern electronic timekeeping.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, B. Applicability of the De Minimis Doctrine",
                        "excerpt": "employers should expect exacting scrutiny of de minimis claims where employees perform off-the-clock work with any degree of regularity."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "WHD says an employer that clearly prohibits work outside scheduled time and enforces that rule may be excused from paying for occasional off-the-clock work it does not know about, but announcing a rule alone is not enough.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, B. Applicability of the De Minimis Doctrine",
                        "excerpt": "if the employer enforces such a rule, it may be excused from compensating occasional off-the-clock work done in violation of such policies and without the employer’s actual or constructive knowledge."
                    },
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, B. Applicability of the De Minimis Doctrine",
                        "excerpt": "The mere promulgation of a rule against such work is not enough."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "WHD says whether improper recording of hours leads to a minimum wage or overtime violation depends on the employee's total hours and pay for the workweek.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Footnote 3",
                        "excerpt": "Whether such improper recording would create a violation of the FLSA’s minimum wage or overtime requirements will depend on whether, after properly accounting for all of an employee’s hours worked during a workweek"
                    }
                ]
            }
        ],
        "required_actions": [
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "Pay non-exempt employees at least the federal minimum wage for all hours worked. The letter describes this existing FLSA requirement.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "General Legal Principles, A. The Fair Labor Standards Act",
                        "excerpt": "The FLSA requires covered employers to pay all non-exempt employees at least the federal minimum wage for all hours worked."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "Pay non-exempt employees overtime at one and one-half times their regular rate for hours worked over 40 in a workweek. The letter describes this existing FLSA requirement.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "General Legal Principles, A. The Fair Labor Standards Act",
                        "excerpt": "the Act requires payment “at a rate not less than one and one-half times the regular rate at which [the employee] is employed” to all non-exempt employees for all hours worked in excess of 40 hours in a workweek."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "Pay for all compensable work the employer knows or has reason to know is being performed, even if it was not requested. The letter describes this as existing law under the FLSA.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "General Legal Principles, A. The Fair Labor Standards Act",
                        "excerpt": "an employer must pay for all compensable work that it knows or has reason to know is being performed."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "If rounding employee time, use a practice that does not, over time, fail to pay employees for all time actually worked. The letter describes this existing Department of Labor rounding regulation under the FLSA (29 CFR 785.48(b)).",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "General Legal Principles, D. Rounding Practices and Aggregate Impact",
                        "excerpt": "This practice, however, is only acceptable if it “will not result, over a period of time, in failure to compensate the employees properly for all the time they have actually worked.”"
                    }
                ]
            }
        ],
        "recommended_actions": [
            {
                "kind": "recommendation",
                "kind_label": "Our suggestion",
                "text": "Consider reviewing your rounding rules to check that they can benefit employees as well as the employer (for example, how late clock-ins are treated) and that they average out over time.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, C. Rounding Policy Compliance with 29 C.F.R. § 785.48(b)",
                        "excerpt": "if employees who clock in up to 7 minutes late are nonetheless credited with starting at their scheduled time and that practice averages out over time to offset any work time lost due to the rounding of early check-ins to the scheduled shift time—then the policy would likely comply with section 785.48(b)."
                    }
                ]
            },
            {
                "kind": "recommendation",
                "kind_label": "Our suggestion",
                "text": "Consider identifying tasks employees do between clocking in and the scheduled shift start, such as handoff reports or finding assignments, and whether that time is being paid.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, A. Compensability of Pre-Shift Activities and Time Spent Waiting at Timekeeping Stations",
                        "excerpt": "at least some of these activities appear to be integral and indispensable to the employees’ principal job duties, and are therefore compensable hours worked."
                    }
                ]
            },
            {
                "kind": "recommendation",
                "kind_label": "Our suggestion",
                "text": "Consider adopting a clear written policy against work outside scheduled shifts, with a way for employees to report extra time, and enforcing it in practice.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, B. Applicability of the De Minimis Doctrine",
                        "excerpt": "employers like the hospital here should consider proactive steps to implement and enforce clear policies prohibiting employees from performing any work-related activities outside their scheduled shift."
                    }
                ]
            },
            {
                "kind": "recommendation",
                "kind_label": "Our suggestion",
                "text": "Consider using your timekeeping system data to test whether any time you exclude as de minimis is actually regular and recordable.",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, B. Applicability of the De Minimis Doctrine",
                        "excerpt": "employers should expect exacting scrutiny of de minimis claims where employees perform off-the-clock work with any degree of regularity."
                    }
                ]
            }
        ],
        "required_actions_assessment": null,
        "applicability": [
            {
                "criterion": "where",
                "label": "Where",
                "answer": "United States, nationwide",
                "kind": "fact",
                "kind_label": "From the source",
                "evidence": []
            },
            {
                "criterion": "employer_type",
                "label": "Employers",
                "answer": "Employers covered by the FLSA that have non-exempt employees; the letter itself answers one public hospital's facts.",
                "kind": "inference",
                "kind_label": "Our analysis",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "General Legal Principles, A. The Fair Labor Standards Act",
                        "excerpt": "The FLSA requires covered employers to pay all non-exempt employees at least the federal minimum wage for all hours worked."
                    },
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Background",
                        "excerpt": "You represent that you are a non-exempt employee of a public hospital that employs approximately 18,000 non-exempt employees."
                    }
                ]
            },
            {
                "criterion": "size",
                "label": "Size",
                "answer": "The letter sets no size threshold; the hospital in the request has about 18,000 non-exempt employees.",
                "kind": "inference",
                "kind_label": "Our analysis",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Background",
                        "excerpt": "You represent that you are a non-exempt employee of a public hospital that employs approximately 18,000 non-exempt employees."
                    }
                ]
            },
            {
                "criterion": "industries",
                "label": "Industries",
                "answer": "All industries with non-exempt employees who clock in, with health care most directly affected since the letter concerns a hospital.",
                "kind": "inference",
                "kind_label": "Our analysis",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Introduction",
                        "excerpt": "This letter responds to your request to the Wage and Hour Division (WHD or Division) for an opinion letter concerning a hospital’s timekeeping and compensation practices."
                    }
                ]
            },
            {
                "criterion": "functions",
                "label": "Functions",
                "answer": "Payroll, human resources, the teams that configure timekeeping systems, and legal or compliance.",
                "kind": "inference",
                "kind_label": "Our analysis",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Background",
                        "excerpt": "the timekeeping system is set up to round these times to the scheduled shift times"
                    }
                ]
            },
            {
                "criterion": "applies_if",
                "label": "Applies if",
                "answer": "You let non-exempt employees clock in before their shift, round clock times to the scheduled shift, or treat short pre-shift periods as de minimis.",
                "kind": "inference",
                "kind_label": "Our analysis",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Introduction",
                        "excerpt": "If employees are in fact performing compensable work before their scheduled shift begins, the employer’s rounding practice at the beginning of the day is neither facially neutral nor neutrally applied"
                    }
                ]
            },
            {
                "criterion": "action",
                "label": "Action",
                "answer": "Review rounding, pre-shift work and off-the-clock policies against WHD's reasoning.",
                "kind": "recommendation",
                "kind_label": "Our suggestion",
                "evidence": [
                    {
                        "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf",
                        "locator": "Opinion, B. Applicability of the De Minimis Doctrine",
                        "excerpt": "employers like the hospital here should consider proactive steps to implement and enforce clear policies prohibiting employees from performing any work-related activities outside their scheduled shift."
                    }
                ]
            }
        ],
        "open_questions": [
            {
                "question": "Are other pre-shift administrative tasks, such as completing accountability documentation, compensable for every job type?",
                "context": "WHD says the answer depends on each job's principal duties and declined to draw broad conclusions for all of the hospital's employees."
            },
            {
                "question": "How regular or how long must pre-shift work be before it can no longer be treated as de minimis?",
                "context": "WHD says daily pre-shift work is unlikely to be de minimis but could not conclude either way on the facts given."
            },
            {
                "question": "Can employers whose facts differ from the requester's rely on this letter?",
                "context": "The letter says it is based exclusively on the facts in the request and that other facts might require a different conclusion."
            }
        ],
        "events": [
            {
                "event_type": "originating_action",
                "label": "Issued",
                "occurred_on": "2026-05-28",
                "summary": "FLSA2026-8: Whether certain pre-shift activities by hospital employees are compensable work and, if so, whether the hospital's practice of rounding employees' clock-in time to their scheduled shift start time is permissible.",
                "source": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf"
            }
        ],
        "corrections": [],
        "sources": [
            {
                "label": "Whether certain pre-shift activities by hospital employees are compensable work and, if so, whether the hospital's practice of rounding employees' clock-in time to their scheduled shift start time is permissible.",
                "publisher": "Wage and Hour Division",
                "role": "primary",
                "url": "https://www.dol.gov/sites/dolgov/files/WHD/opinion-letters/FLSA/FLSA2026-8.pdf"
            }
        ]
    }
}