Colorado’s overtime regulations create some of the most complex compliance challenges in the United States, particularly for healthcare employers who must navigate daily overtime requirements, consecutive hour rules, and weekly standards that exceed federal minimums. Understanding these Colorado overtime laws is essential for healthcare practices operating in the state, as violations can result in significant penalties and back pay obligations.
At HR for Health, we help healthcare practices understand these intricate regulations while maintaining operational efficiency and ensuring proper employee compensation.
Understanding Colorado’s Overtime Framework
Colorado’s overtime requirements operate within the Colorado Overtime and Minimum Pay Standards (COMPS) Order, which establishes standards that significantly exceed federal Fair Labor Standards Act (FLSA) requirements. While federal law only requires overtime after 40 hours in a workweek, Colorado employment law adds daily and consecutive hour overtime triggers that create additional compensation obligations.
The COMPS Order applies to most employees working in Colorado, with limited exemptions for specific industries and job classifications. Healthcare employers must understand that Colorado’s standards take precedence over federal requirements when they provide greater employee protections, meaning practices must comply with whichever standard is more favorable to employees. HR for Health automatically monitors and flags changes to state-level labor laws like COMPS updates. With built-in compliance recommendations and alerts, you’ll always know when new rules affect your overtime obligations without having to do your own manual research.
Daily Overtime Requirements in Colorado
Colorado’s daily overtime requirements mandate overtime compensation for any work exceeding 12 hours in a single workday, regardless of total weekly hours worked. This rule applies to most non-exempt employees and creates obligations that don’t exist under federal law.
For healthcare practices, the 12-hour rule significantly impacts scheduling decisions. A nurse working a 13-hour shift must receive overtime pay for the 13th hour, even if they only work three such shifts in a week (totaling 39 hours). This requirement often catches healthcare employers off guard, particularly those accustomed to federal standards that focus solely on weekly hour totals.
The workday definition becomes crucial for compliance. Colorado defines a workday as a consecutive 24-hour period starting when the employee begins work. This means a nurse starting at 7 AM begins a workday that extends until 7 AM the following day, and any work beyond 12 hours within that period triggers overtime obligations.
Healthcare practices must also consider how the 12-hour rule applies to employees who work split shifts or return to work after brief breaks. If an employee works 6 hours, leaves for 2 hours, then returns for 7 more hours, they’ve worked 13 hours within a single workday and earned 1 hour of overtime compensation.
HR for Health’s time tracking tools help you monitor exactly when employees cross Colorado’s daily 12-hour threshold. Our system sends real-time alerts when overtime kicks in, and automatically updates timesheets to save you from miscalculations and missed hours.
Consecutive Hour Overtime Provisions
Colorado’s consecutive hour overtime rule requires overtime pay after 12 consecutive hours of work, regardless of when the workday officially begins or ends. This provision addresses situations where employees work extended periods that might span multiple calendar days or scheduled workdays.
For healthcare providers, consecutive hour overtime often applies during emergency situations, holiday coverage, or when employees cover for absent colleagues. A respiratory therapist who works their regular 8-hour day shift and then covers an evening shift would trigger consecutive hour overtime after 12 total hours of work.
Weekly Overtime Standards
Weekly overtime calculations in Colorado require careful attention to how hours are counted and which rates apply. Employees who work both daily and weekly overtime don’t receive double compensation for the same hours. Instead, they receive the higher of the applicable overtime rates for those hours.
For example, a medical technician working four 11-hour shifts (44 total hours) would receive regular pay for the first 40 hours and overtime pay for 4 hours based on weekly overtime rules. If the same employee worked four 13-hour shifts (52 total hours), they would receive overtime for the 13th hour of each shift under daily overtime rules and additional overtime for any weekly hours exceeding 40, calculated to ensure they receive the maximum benefit. Whether employees work multiple roles or variable shifts, HR for Health’s payroll engine calculates weekly and daily overtime using the most favorable rule for employees automatically. You get accurate, compliant overtime pay, every time.
Colorado Overtime Exemptions
Colorado overtime exemptions apply to certain categories of healthcare employees, though these exemptions are narrower than many employers assume. Licensed healthcare professionals may qualify for professional exemptions if they meet specific criteria related to education, licensing, and job duties.
Physicians, nurse practitioners, and other advanced practice providers often qualify for professional exemptions when their primary duties involve applying advanced medical knowledge requiring specialized education. However, the exemption doesn’t automatically apply to all healthcare workers with professional licenses: registered nurses, licensed practical nurses, and medical technologists typically remain eligible for overtime compensation. Employers must ensure that employees meet both a salary threshold and a duties test to qualify for exemption. Misclassification remains one of the most common, and costly, compliance errors. HR for Health clients receive access to our team of dedicated healthcare-specific HR compliance experts for assistance with determining exempt vs. non-exempt status on a case by case basis.
1. Professional Exemption
Healthcare professionals may qualify for this exemption only if they meet all of the following:
- Primary duty involves work requiring advanced knowledge in a field of science or learning
- This knowledge is customarily acquired through prolonged, specialized education
- The employee is actually working in the field they were trained in
- They are paid a salary of at least $1,086.25 per week ($56,485/year) as of 2025.
Note: Being licensed or performing clinical tasks is not enough to meet the exemption; the role must be primarily intellectual and require discretion and independent judgment.
2. Executive or Supervisory Exemption
To qualify, an employee must:
- Supervise at least two full-time employees
- Have authority to hire, fire, or meaningfully recommend personnel decisions
- Spend at least 50% of their time on supervisory duties
- Be paid a salary of at least $1,086.25/week ($56,485/year)
3. Administrative Exemption
This applies only if the employee:
- Performs non-manual work directly related to business operations or management
- Exercises independent discretion and judgment on matters of significance
- Reports directly to an executive decision-maker
- Is salaried at $1,086.25/week ($56,485/year) or more
4. Highly Compensated Employee Exemption
An employee earning at least $127,091 per year (2.25× the standard salary threshold) may qualify as exempt if they regularly perform at least one duty of an executive, administrative, or professional employee. However:
- Their primary duty must be non-manual
- They still must perform qualifying duties, high pay alone does not guarantee exemption
5. Doctors Exception (Salary Test Not Required)
Physicians, dentists, and surgeons, along with attorneys and teachers, are exempt from overtime without regard to salary level. This applies only to employees fully licensed and practicing in their licensed capacity.
Calculating Overtime Pay in Colorado
Overtime calculations in Colorado require understanding how to determine the regular rate of pay and apply appropriate multipliers based on which overtime trigger applies. The regular rate includes not only base hourly wages but also certain bonuses, shift differentials, and incentive payments that must be factored into overtime calculations.
Key calculation considerations for healthcare practices include:
- Shift differential integration – Adding differentials to base rates before calculating overtime premiums
- Bonus allocation methods – Distributing periodic bonuses across all hours worked in the applicable period
- Multiple rate scenarios – Handling employees who work different roles with different pay rates during the same workweek
- On-call compensation inclusion – Incorporating on-call payments into regular rate calculations
- Holiday and premium pay interactions – Ensuring holiday premiums don’t create incorrect overtime calculations
With HR for Health, your payroll system calculates overtime inclusive of shift differentials, multiple rates, and on-call pay automatically and in compliance with Colorado law. No spreadsheets, no guesswork.
Break Time and Overtime Interactions
Colorado’s meal and rest break requirements interact with overtime calculations in ways that healthcare practices must understand to maintain compliance. Break time regulations specify that meal breaks of 30 minutes or longer don’t count toward hours worked when employees are completely relieved of duties.
However, healthcare environments often require employees to remain available during meal breaks to respond to patient emergencies. When healthcare workers must monitor patients, answer calls, or remain on-site during meal periods, these breaks become compensable time that counts toward overtime thresholds.
Record-Keeping Requirements for Overtime
Colorado record keeping requirements for overtime compliance extend beyond basic timekeeping to include detailed documentation of hours worked, break periods, and overtime calculations. Healthcare practices must maintain accurate records for each employee showing daily hours, weekly totals, and overtime compensation.
Required documentation includes:
- Daily time records showing start times, end times, and total hours worked each day
- Break documentation indicating when meal breaks were taken and their duration
- Overtime calculation worksheets demonstrating how daily, consecutive hour, and weekly overtime were determined
- Rate determination records showing how regular rates were calculated for employees with multiple pay rates or bonuses
- Exemption documentation supporting the classification of exempt employees including job descriptions and salary records
Record retention requirements mandate keeping overtime documentation for at least three years, with some records requiring longer retention periods. Healthcare practices should implement systematic record-keeping procedures that capture required information automatically rather than relying on manual processes that may miss critical details. HR for Health stores all of your employee data and timesheets in a cloud-based system with full audit trails. If the Department of Labor ever comes knocking, you’ll have everything you need.
Common Overtime Violations in Healthcare
Healthcare practices frequently encounter overtime violations due to the complexity of Colorado’s requirements and the unique challenges of healthcare scheduling. The most common violations include misclassifying employees as exempt, failing to calculate daily overtime properly, and inadequate tracking of consecutive hours worked.
Misclassification violations often involve nurses, medical technicians, or administrative staff who don’t meet the stringent requirements for overtime exemptions. Even employees with professional licenses or management responsibilities may remain eligible for overtime if their duties don’t align with exemption criteria.
Calculation errors frequently occur when practices attempt to manage Colorado’s multiple overtime triggers manually. Complex scenarios involving shift differentials, bonuses, and varying schedules require sophisticated tracking systems to ensure accurate compensation. HR for Health helps prevent the most common overtime violations by giving you real-time alerts and access to certified HR advisors if you’re unsure about classification or scheduling rules.
Technology Solutions for Colorado Overtime Compliance
Modern technology offers powerful solutions for managing Colorado overtime compliance in healthcare settings. Advanced timekeeping systems can automatically track daily hours, consecutive work periods, and weekly totals while calculating appropriate overtime rates based on complex pay structures.
Key features for Colorado compliance include:
- Automatic payroll calculations that handle multiple overtime triggers and complex rate determinations
- Overtime Alerts that notify you or your managers when team members have exceeded standard work hours
- Integration capabilities that connect timekeeping with scheduling and payroll systems
- Audit trail functionality that maintains detailed records for compliance documentation
HR for Health offers a healthcare-specific HR platform with built-in overtime compliance tools including alerts, audit-ready time tracking, and integrated payroll logic that accounts for Colorado’s unique labor rules.
Let HR for Health Handle the Complexity for You
Colorado labor law continues to evolve, with regular updates to overtime requirements, exemption thresholds, and enforcement procedures. Healthcare practices must stay informed about these changes to maintain ongoing compliance and avoid costly violations. HR for Health specializes in helping healthcare practices navigate Colorado’s complex overtime requirements while maintaining operational efficiency. From tracking new law updates and a dedicated HR support team to built-in timekeeping and overtime pay calculations, HR for Health gives you a full platform designed for Colorado healthcare practices. No more guessing, no more gaps, just peace of mind. Contact us today to learn how our specialized solutions can help you manage overtime compliance while optimizing your scheduling and compensation practices.
