Employee Time Tracking Rules: When to Track Time for Off-Site Projects

When employees leave the office to work on a project, visit a customer, attend training, or travel to another job site, tracking their time can be complicated. Businesses need to understand which activities count as hours worked, when travel time must be paid, and how to ensure employees accurately record their hours.

Failing to track work time correctly can lead to unpaid wages, overtime violations, and potential legal liability. However, you don’t necessarily need to pay employees for every minute spent traveling away from their regular workplace.

Under the federal Fair Labor Standards Act (FLSA), covered nonexempt employees generally must be paid for all compensable hours worked, including qualifying work performed away from the employer's premises. But here's what business owners need to know about off-site time tracking.

Why Off-Site Employee Time Tracking Matters

Employees may work at customer locations, construction sites, temporary assignments, or home offices where traditional time clocks are unavailable. They may also travel between locations or complete project tasks outside their normal schedules.

Without clear procedures, employees can unintentionally leave out compensable time. Accurate time tracking helps you:

• Pay employees correctly for all compensable hours worked.
• Calculate overtime accurately.
• Maintain required payroll records.
• Identify work performed before or after scheduled shifts.
• Monitor project labor costs and improve workforce planning.

What Does the FLSA Consider as Hours Worked?

The Fair Labor Standards Act (FLSA) generally requires employers to compensate nonexempt employees for work they require or permit employees to perform, which sets the federal baseline for wage and hour laws in the U.S. This includes qualifying work completed outside normal business hours or away from the regular workplace.

For example, an employee who spends 30 minutes at home completing a required project report after a scheduled shift generally must record that time. The same principle may apply to required work calls, project preparation, and other job duties performed outside the office.

You cannot avoid paying for compensable work simply because it was unauthorized, performed at home, or completed outside scheduled hours. A policy prohibiting unauthorized overtime does not eliminate the obligation to pay for overtime actually worked (overtime pay is measured by workweek per the FLSA, which is a fixed 168-hour period; some state laws may differ).

For more information, see the U.S. Department of Labor's Fact Sheet #22: Hours Worked Under the FLSA.

Does sending a text message to an employee after work hours count as compensable work time?

Yes, asking a work-related question via text or phone call to a non-exempt employee after hours would be considered time worked, which is compensable. This would be the case even if the manager intended the employee to not view or respond to it until the next workday.

Does Working Away from the Office Mean Travel Time Must Be Paid?

Not necessarily. Working away from the regular workplace does not automatically mean all travel time is compensable, nor does it mean the time is unpaid. The answer depends on the type of travel, when it occurs, the employee's duties, and the circumstances surrounding the trip.

You should distinguish between ordinary commuting, travel between job sites, special assignments, overnight travel, and work performed before or after a scheduled shift.

Ordinary Commuting: Traveling from Home to Work

Ordinary travel between an employee's home and regular workplace is generally not compensable under the FLSA, even when the employee travels to a different work location each day.

For example, a technician who drives directly from home to the first customer appointment generally does not need to be paid for the ordinary commute.

However, the circumstances may change when an employee performs required work during the trip or must report to a designated location before traveling to the job site.

Examples include:

• Picking up supplies: Required work-related stops and subsequent travel to a job site may be compensable.
• Reporting to the office first: Travel from a required reporting location to a project site generally counts as work time.
• Transporting coworkers: Required transportation duties may affect which portions of a trip are compensable.

You should establish clear expectations for employees who report directly to customer locations or project sites.

Travel Between Job Sites During the Workday

Travel between job sites during the workday generally counts as hours worked. This includes travel between customer appointments, construction projects, facilities, and other assigned locations.

For example, a technician spends the morning repairing equipment at one customer's location, then drives 25 minutes to another customer for an afternoon appointment. The 25 minutes spent traveling between assignments generally must be included in paid hours.

A timekeeping system that records only time spent performing hands-on work at each location can undercount compensable hours. Employees should have a way to record travel between assignments.

Special One-Day Assignments in Another City

Travel to and from a special one-day assignment in another city is generally compensable under the FLSA, except that employers may deduct the time employees normally spend commuting to their regular workplace.

For example, an employee normally commutes 30 minutes each way but must travel two hours each way to a special assignment in another city. Under the federal rule, the employer may generally exclude the employee's normal one-hour round-trip commute from the four hours of travel.

Employers should not automatically treat longer trips to temporary assignments as unpaid commuting time.

Overnight Business Travel

Overnight business travel has additional rules. Generally, travel as a passenger during an employee's normal working hours counts as work time, including corresponding hours on days the employee would not normally work.

For example, if an employee normally works from 8 a.m. to 5 p.m. and takes a flight from 10 a.m. to 1 p.m. for a business assignment, those three hours of qualifying travel generally count as work time.

By contrast, passenger travel outside normal working hours is generally not compensable when the employee is relieved from work duties. However, actual work performed during the trip must be evaluated separately.

You should assess each travel period based on the employee's normal schedule and the circumstances of the trip. The Department of Labor provides additional information in its travel-time guidance.

Work Performed Before or After a Scheduled Shift

Employees may perform compensable work before arriving at a job site or after leaving it. You generally must count work you know or have reason to believe is being performed.

Examples include:

• A project manager reviews plans at home before traveling to a site.
• A sales employee prepares a required client presentation after hours.
• A technician completes required service notes after the scheduled shift.
• A supervisor handles work-related calls or messages outside normal hours.

These activities generally must be recorded when they constitute work that you, as the business owner, permit or require. You may enforce scheduling policies, but you must still pay for compensable work actually performed.

Do State Laws Apply, or Does the FLSA Prevail?

The FLSA establishes a federal baseline, but it is not the only law employers may need to follow. State and local wage-and-hour laws, including state labor laws and other state and local laws, may impose additional or more protective timekeeping and record-keeping requirements. You generally must comply with the applicable requirements that provide greater protection to employees.

State laws may differ regarding overtime rules, meal periods, recordkeeping, and compensable travel time. Do not assume the federal rules answer every question and remember that labor laws can vary by jurisdiction.

If your business operates in multiple states, you should review the laws that apply where employees perform work. When using monitoring or location-tracking tools, assess applicable privacy laws and provide advance notice where required. If the rules are unclear or appear to conflict, contact qualified employment counsel to help determine the appropriate approach and support legal compliance.

You should also confirm employee classifications. Nonexempt employees generally are entitled to overtime at no less than one and one-half times their regular rate for hours worked over 40 in a workweek under federal law; some state laws have daily requirements. Being paid a salary or holding a particular job title does not automatically make an employee exempt.

Practical Examples of Off-Site Work

Consider the following examples of common business situations:

Construction project: An employee reports to the company yard to collect tools before traveling to a project site. The employer generally must count required work at the yard and qualifying travel from the reporting location to the site.

Multiple customer appointments: A service technician visits three customers in one day. The technician records work at each location and travel between appointments, while ordinary commuting is evaluated separately.

Off-site training: An employee attends required training at a hotel. The training time generally counts as work time; travel time must be evaluated under the relevant travel rules.

Project work at home: A nonexempt employee spends 30 minutes completing a required report after a full shift. The employee should record the additional time so it can be included in total hours and overtime calculations when applicable.

Overnight installation: A technician travels out of state for a two-day project. The employer records the installation work and evaluates each travel period based on its timing, the employee's normal working hours, and whether the employee performed work during the trip.

These examples demonstrate why you shouldn’t rely on a generic rule such as “pay only for time at the job site.”

Establish Clear Time-Tracking Procedures

Once employers understand which activities may be compensable, they need a practical process for recording those hours. Consider these best practices:

1. Define When Employees Should Record Time

Explain when employees should begin recording work, including when they should clock in, how they should record travel, and when the workday ends. Clear time clock rules should define start-of-day, end-of-day, and off-site recording expectations. Address reporting to designated locations, direct-to-customer assignments, and required work outside scheduled shifts.

2. Create Separate Categories for Work and Travel

Use timekeeping categories for project work, travel between job sites, special assignments, and other relevant activities. These categories help managers review records, but the actual circumstances and applicable laws determine whether time is compensable.

3. Require Employees to Report All Work

Employees should record all time worked, including work outside scheduled shifts. They should also track each meal period (breaks of 30 minutes or longer can be unpaid only if the employee is completely relieved from duty).

Time-tracking systems must accurately log break durations; short rest breaks of 20 minutes or less count as paid work time. Employees should not be instructed to omit time because it was unauthorized or performed away from the workplace. Again, you must compensate employees for all work performed, including unreported after-hours tasks once known.

4. Review Time Entries Before Payroll

Supervisors should look for missing travel periods, unusual gaps, and work outside scheduled hours before the payroll process. A good business practice is to require manager approval before employee timesheets are processed to support payroll accuracy.

Investigate discrepancies rather than automatically deleting or reducing reported time. Managers may enforce overtime approval policies separately as a workplace rule, but payroll compliance still requires paying for time actually worked to help prevent payroll errors.

5. Maintain Accurate Records

The FLSA requires covered employers to maintain certain records for nonexempt employees, including hours worked each workday and total hours worked each pay period. You must maintain records under applicable federal law, state laws, and local requirements, including accurate time records and wages paid (per the FLSA, payroll records are generally kept for at least three years, while basic supporting timekeeping records must be retained for at least 2 years).

Some states may vary from the FLSA record-requirements. For example, New York requires employers to keep time records for six years; Illinois requires daily work-hour records for three years; and Texas has no specific time clock laws but still requires accurate records for two years.

6. Use Technology to Simplify Tracking

Mobile timekeeping tools can help off-site employees record hours, select project codes, and submit corrections, as well as review and verify recorded hours before payroll. Integrated timekeeping and payroll systems can also reduce manual entry. When digital systems sync with payroll, they can improve attendance tracking, support accurate payroll, strengthen payroll calculations, and help you identify potential overtime before payroll is finalized.

If you choose a time clock system with location features or biometric time clocks, you may need to address written consent, secure storage, and applicable legal compliance requirements.

At Stratus HR, we have a built-in time tracking tool in our employee mobile app that allows workers to log time at different job locations for accurate job costing. It also allows employers to geofence specific locations for accurate time tracking. Contact your Stratus HR rep for more information.

Common Time-Tracking Mistakes to Avoid

When it comes to time tracking, watch for these common problems:

• Paying only for time spent physically at a job site.
• Assuming all travel time is unpaid.
• Ignoring required work performed before or after scheduled shifts.
• Assuming salaried employees never need to track time.
• Automatically rejecting unauthorized hours that were actually worked.
• Applying the same rules across every state without reviewing local requirements.
• Failing to investigate incomplete or inconsistent time records.
• Using unlawful rounding practices when employees log time (including recorded clock out time) in ways that create payroll risk.

If employers round time, the FLSA generally allows rounding to the nearest 5, 6, or 15 minutes; for 15-minute increments, the 7-minute rule applies, and rounding must average out fairly for both employers and employees rather than favor the employer. Keep in mind that employers must pay compensable time for any work permitted or required to be done after clocking in, even with rounding practices. California courts have also become increasingly hostile to rounding practices, so multi-state employers should review state-specific rules carefully.

Keep in mind that exempt employees may still track time for project management, job costing, or internal planning. However, they are generally not entitled to overtime pay and are typically paid on a salary basis, regardless of hours worked.

Conclusion: Accurate Time Tracking Starts with Clear Expectations

When employees work on projects away from their regular workplace, you must consider the type of work performed, when travel occurs, and which federal, state, and local rules apply.

Ordinary commuting is generally unpaid under the FLSA, while travel between job sites during the workday is generally compensable. Special assignments, overnight travel, and work performed before or after a shift require closer evaluation. Detailed tracking most often applies to hourly employees, especially non-exempt employees who remain eligible for overtime, while other employees may have different recordkeeping obligations depending on their classification.

The most effective approach combines a clear written policy, employee training, accurate timekeeping tools, and consistent payroll review. When employees understand how to record off-site work and managers know how to review those records, businesses are better positioned to pay employees correctly, maintain compliance, and manage project labor costs.

Stratus HR helps businesses manage HR processes such as developing time tracking policies and providing HR tech to accurately record time punches. By reviewing timekeeping practices with knowledgeable HR professionals, you can help identify potential gaps and establish procedures that support your business.

To get started, book a free consultation and our team will contact you shortly.