FREQUENTLY ASKED QUESTIONS
The purpose of the Notice is to inform you of the existence of a collective action lawsuit against R1. You are receiving the Notice because records indicate you were an hourly-paid, non-exempt employee employed by R1 as a remote employee who used R1’s electronic timekeeping system to record hours worked and/or work performed from February 2, 2021 to the present. Therefore, the Court has authorized that the Notice be sent to you, to explain what the lawsuit is about, so that you can decide whether to opt in (join the lawsuit).
Please note that the Court has not ruled on the merits of the lawsuit. The Court has only ruled that it is important that you be notified of the existence of the lawsuit so that you can determine (a) how to protect your rights and (b) whether you wish to join it.
Plaintiff, Linda Crouse (“Plaintiff”), brought this action under the Fair Labor Standards Act (“FLSA”) on behalf of herself and all Associates who worked for R1 during the past three years. Specifically, Plaintiff alleges that R1 violated the FLSA by requiring Associates to routinely perform certain pre-shift activities off-the-clock without pay. These activities include turning on or warming up their computers, booting up the computers, signing into Windows and logging into the time keeping system before they were able to clock in to the timekeeping system; and troubleshooting technical problems with the computers, networks, programs/applications, and/or phone prior to clocking in. Plaintiff contends that R1’s training and policies prohibited Associates from including these pre-shift activities in their compensable time. Plaintiff therefore alleges that she and other CSRs were forced to perform all the above referenced tasks off the clock.
Plaintiff alleges that she and all employees similarly situated are entitled to recover unpaid overtime pay, liquidated damages (equal to the unpaid overtime pay) and interest, attorneys’ fees, and costs associated with bringing this lawsuit.
R1 contests all claims that have been asserted and denies any wrongdoing or liability.
If you are an Associate as defined on page 1 of the Notice you received, you may choose to join this suit (that is, you may “opt in”). To opt in, you must submit a “Consent to Join” form. The Consent to Join form is enclosed with the Notice your received. You may use the enclosed envelope you received to mail your form, or you may fax it or e-mail it to the claims administrator (whose information is available in Question 7, below), or you may submit your form online HERE. The deadline is March 17, 2025. Forms must be postmarked by that date to be valid. Late forms will not be accepted.
If you file a Consent to Join form by following the instructions, you will be bound by the judgment (the final result of the lawsuit), whether favorable or unfavorable (that is, whether the Plaintiffs win the case against R1 or not).
Plaintiffs’ attorneys will not charge you directly for their work in this case. If there is no recovery (i.e., if Plaintiffs recover no money from R1), you will not have to pay the attorneys for any of their work. If there is a recovery, Plaintiffs’ attorneys will receive whatever attorneys’ fees the Court orders. Those fees may be subtracted from the recovery obtained from R1, be paid separately by R1, or they may be a combination of the two.
If you join this lawsuit, you are choosing to be represented by Plaintiffs’ counsel and the Named Plaintiff who brought this case to make decisions and agreements on your behalf concerning the lawsuit. These decisions and agreements will then be binding on you.
If you choose not to join this lawsuit, you will not be affected by any judgment in this lawsuit on this FLSA claim, whether favorable or unfavorable. If you choose not to join this lawsuit, you may file your own lawsuit and select the attorney of your choice. However, if you do not join this lawsuit, you will not be able to receive any money recovered in this lawsuit.
Federal law prohibits R1 from retaliating against you in any way (for example, firing you, giving you unfair reviews, cutting your pay, failing to promote you, etc.) for exercising your rights under the FLSA (for example, by joining this lawsuit or by providing evidence in support of the Plaintiffs’ claims).
If you choose to join this lawsuit, you will be represented by the Named Plaintiffs through their attorneys. They are:
SOMMERS SCHWARTZ, P.C.
Matthew L. Turner
Paulina R. Kennedy
One Towne Square, Suite 1700
Southfield, Michigan 48076
Telephone: 1-800-418-5175
Fax: 248-936-2147
Email: FLSA@sommerspc.com
Crouse v R1 RCM
c/o Atticus Administration
PO Box 64053
St. Paul, MN 55164
Email: R1RCMOvertimePayLawsuit@AtticusAdmin.com
Telephone: 1-800-418-5175
Website: www.R1RCMOvertimePayLawsuit.com
If you want further information about this lawsuit, or have questions about the procedure or deadline for filing a “Consent to Join,” please contact Plaintiffs’ Counsel.
The Notice and its contents have been authorized by the United States District Court for the District of Utah, the Honorable David B. Barlow presiding. The Court has taken no position regarding the merits of Plaintiffs’ claims or of R1 RCM’s defenses.