The hard part of hotel pay compliance is that the rules stack: federal overtime, state daily overtime and premium pay, a citywide minimum, and a hotel-worker ordinance can all govern the same Tuesday. This auditor takes one worker's real week — shift times, breaks, square footage cleaned, pay received — resolves which layers apply on that date, and itemizes everything owed, with each step cited. Inputs never leave your browser.
How the audit is layered#
Each run works through six stages, in the order a careful auditor would:
- Wage-floor resolution. Federal, state, citywide, and hotel-ordinance floors are resolved for each day of the week from verified rate schedules — the highest controls. When a scheduled step lands mid-week (a Los Angeles hotel with 60+ rooms jumps from $22.50 to $25.00 on July 1, 2026, and picks up a $4.25/hour health benefit payment the same day), the audit flags the step and compares each day's pay against that day's floor; the FLSA regular rate stays a weekly figure.
- Hour classification. Daily overtime and double time (CA after 8 and 12 hours), seventh-consecutive-day rules with the §556 exemption, and the weekly 40 — without pyramiding. Nevada's rolling 24-hour workday (NRS 608.0126) and Colorado's 12-consecutive-hour trigger (COMPS Rule 4.1.1(C)) are computed from the actual shift segments, so double-backs and cross-midnight runs surface the overtime a calendar grid misses.
- The regular rate. Service charges and non-discretionary bonuses are wages that raise the rate (29 CFR 531.55, 778.211) — and with it every overtime premium, California meal/rest premium (Ferra), and workload double-pay hour.
- Tip-credit validation. No-credit states enforce the full cash floor; New York runs the Part 146 tiers, the weekly tip-average thresholds that zero the credit, the written-notice trap, and the 2-hour/20% daily rule; Chicago computes the tipped cash wage as a percentage of the city minimum. When the wage floor steps mid-week, the credit ceiling is the floor in force on each day, so the credit is now resolved exactly per day and expressed as an hours-weighted effective rate — not approximated against a single weighted floor — while the weekly tips-cover-the-credit test (29 CFR 531.59(b)) stays a workweek figure.
- Premium pay. California meal-period timing (end of the 5th hour), rest-break major fractions, split-shift offsets, and reporting-time pay; New York spread-of-hours and call-in pay at the right rates (basic minimum for unworked hours, no tip credit); Illinois ODRISA meal periods (a 20-minute break by the fifth hour of a 7.5-hour shift, plus one per additional 4.5 hours) and Kentucky's middle-of-shift meal and paid 10-minute rest breaks, surfaced as disclosures since neither carries a formulaic premium.
- Ordinance overlays. Housekeeping workload caps with their square-footage adjustments and the all-hours double-pay or Seattle 1.5× premium; healthcare expenditure obligations; service-charge pass-through flags.
A worked example#
Los Angeles housekeeper, week of July 6, 2026. 80-room hotel, $25.00/hour, five 9-hour days (8:00–5:30 with a 30-minute meal). Tuesday's meal started after 5.5 hours; Wednesday she cleaned 4,200 sq ft. The auditor finds: 40 straight + 5 daily-OT hours; a $25.00 meal premium for Tuesday (the meal came after the end of the fifth hour); Wednesday's prorated cap is 3,937.5 sq ft (3,500 × 9÷8), so the whole 9-hour day is owed at double time — $212.50 beyond pay already due; and $191.25 in health benefit payments ($4.25 × 45 hours). Total: $1,616.25 against $1,187.50 a naive payroll run would produce.
What this tool does not do#
- It audits one worker and one workweek at a time — it is not a payroll system, and multi-week bonus apportionment (29 CFR 778.209) is out of scope.
- Deep premium rules cover 15 jurisdictions — California, New York, Colorado, Nevada, Alaska, Washington, Oregon, Massachusetts, New Jersey, Connecticut, New Hampshire, Rhode Island, Illinois, Kentucky, and D.C.; other states run at the FLSA baseline plus their overtime parameters, with the gaps flagged, not silently skipped.
- Kentucky's seventh-day overtime (KRS 337.050) — time-and-a-half for the seventh day when an employee works all seven days and is permitted to exceed 40 hours — overlaps the FLSA weekly overtime already computed and turns on the 40-hour proviso, so the audit flags it for review rather than pricing the same hours twice. The fluctuating-workweek method (29 CFR 778.114) and the §7(i) and §7(g)(2) elections are likewise out of scope for this release.
- Workload ordinances whose parameters could not be verified against primary sources (LA County, and adjustments in Glendale and Long Beach) are disclosed rather than guessed — when square footage is entered under one of them, the audit reports the unmodeled exposure as a finding instead of staying silent.
- Nevada's rolling 24-hour daily overtime and Colorado's 12-consecutive-hour trigger are modeled from the shift segments entered. The models label their assumptions in the step list: Nevada windows anchor at each day's first shift start, and for Colorado — whose order excludes duty-free meal periods from the consecutive count without defining when a break ends a run — gaps over an hour are treated as breaking the run.
Background: overtime & the regular rate · the hotel ordinance map · meal & rest breaks. Pair the findings with the exposure modeler to see what a pattern costs. This tool is educational and illustrative — see the disclaimer.