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 shift-anchored 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. Additional LA cash health wages enter the weekly rate before premiums. The cash amount follows each day’s effective rate if a step occurs mid-week. 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 3× pay for actual above-limit cleaning time; healthcare expenditure obligations; service-charge pass-through flags.
A worked example#
Los Angeles housekeeper, week of July 6, 2026. An 80-room hotel pays a $25.00 base plus the $4.25 additional cash health wage. The employee works five 9-hour days (8:00–5:30 with a 30-minute meal), with Tuesday's meal starting after 5.5 hours and 4,200 sq ft cleaned Wednesday. Ordinary wages are $1,316.25 for all 45 hours. At the ordinary pre-workload rate of $29.25, Wednesday's nine-hour workload increment is $263.25, with no overtime offset. That workload payment enters the weekly regular rate: ($1,316.25 + $263.25) ÷ 45 = $35.10. The five daily-overtime hours add $87.75, and Tuesday's meal premium adds $35.10, producing $1,702.35.
The local workload increment uses the ordinary rate before that increment; the federal weekly rate then includes it under 29 CFR 778.207. The model does not repeatedly feed the workload payment back into its own local basis. See the housekeeper capstone for the separate computations. The no-workload 48-hour cash example remains $1,521.00.
What this tool does not do#
- LA cash health payments are modeled as additional hourly wages on all worked hours, included in the regular rate. Actual qualifying benefit-plan contributions are not required on overtime hours and require a separate calculation. The bonus input assumes an includable production bonus earned across all hours; California flat-sum bonuses require a different allocation.
- 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.
- The eight modeled workload ordinances use their verified local counting and proration rules. Seattle requires the actual cleaning time above the limit; Glendale requires per-room 500-square-foot adjustments. Enter those facts to price the premium. Collective-bargaining waivers and fact-specific exceptions require separate review.
- Nevada's shift-anchored 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.