Home Care Employers on the Hook for Travel Time Between Purchasers

On October 7, 2025, the U.S. Supreme Court declined to listen to an attraction in a case difficult whether or not house well being aides have to be paid for time spent touring between purchasers’ houses. The court docket’s denial of certiorari leaves in place a Third Circuit (which incorporates Delaware, Pennsylvania, and New Jersey) ruling that such journey time is compensable below the Fair Labor Standards Act (FLSA).

The case, Nursing Home Care Management Inc. v. Secretary of Labor, arose after the U.S. Department of Labor sued a Pennsylvania-based house well being company for failing to pay house well being aides for time spent touring from one shopper’s house to a different throughout the identical workday.

The Third Circuit held that this inter-client journey is “integral and indispensable” to the aides’ principal job duties and subsequently constitutes compensable work below the FLSA. The court docket relied on the Department of Labor’s steady workday doctrine, which requires employers to pay workers all the time between their first and final principal actions of the day, even when that point consists of intervals of journey or inactivity.

While employers are usually not required to compensate workers for commuting to or from work, the Portal-to-Portal Act doesn’t exempt journey that happens after the workday begins. The Third Circuit emphasised that house well being aides can not present providers in purchasers’ houses with out touring to them, and such journey is a mandatory element of the job.

Importantly, the Third Circuit clarified that solely mandatory journey between job websites is compensable — not marginal journey reminiscent of going house, to a different job, or private errands. But for aides working with a number of purchasers in a day, journey between these appointments have to be counted as hours labored.

The ruling reinforces the Department of Labor’s longstanding interpretation of the FLSA and indicators to employers — particularly in industries with cell workforces — that they need to rigorously observe and compensate intra-day journey time the place such journey is tied to core job duties.

Practical Takeaway for Employers:

• Travel between job websites through the workday is compensable. Employers should pay for this time if the journey is required to carry out principal work duties.
• The ruling is particularly related to house well being, private care, and subject service industries, the place workers often journey between buyer areas.
• Employers ought to evaluate timekeeping and scheduling practices to make sure they seize journey time precisely and supply acceptable compensation below the FLSA.

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