What does Bolina mean for your Adult Family Home?
The Washington Supreme Court's Bolina decision is a good moment to look at how caregiver time, pay and payroll records really work in your home. Five questions to start with.
Why this matters
On July 9, 2026, the Washington Supreme Court filed its decision in Bolina v. AssureCare Adult Home LLC, a case about live-in caregivers in Adult Family Homes. Rather than assume one answer fits every home, we think owners should use this moment to look at how caregiver time, pay and payroll records really work in their own homes.
The questions
Five questions worth asking after Bolina
Answer each one for your own home. Nothing is sent anywhere. It is just for you.
Do you have live-in caregivers?
Can you explain how work time is told apart from time when the caregiver is truly off duty?
Could you show the hours actually worked?
Pick one caregiver and go back six months. Could your records show the hours they actually worked each day and each week? Washington requires payroll records to include both.
Do you see overtime coming before payday?
Can you tell when a caregiver is close to 40 hours, before the next shift adds more overtime?
Are breaks really breaks?
During a meal break, is the caregiver truly free from duties? L&I says a meal break must be paid if the worker stays on duty, has to stay on call at the home, or gets called back to work.
Do your payroll and L&I reports tell the same story?
Can you explain how your schedules and time records flow into payroll and your workers' comp reports? L&I has a separate category for adult family homes and a special way to report caregivers who work 24-hour shifts.
Answer the questions above to see where you stand.
Walk through it with usThe bigger question
Payroll should do more than pay people correctly. It should help you understand your home.
Sources
Where this comes from
Bolina v. AssureCare Adult Home LLC, Washington Supreme Court No. 103519-5 (July 9, 2026)
WAC 296-128-010, payroll records
The series
More briefs in the series
Complimentary · 20 to 30 minutes
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