This is what we're doing right now to contain our fence-jumper, Travis -- he's spending most of the day in the "wobbler den" on the front porch of Widget's House. When we let him out in the morning, he gets to race around the yards while we're over there scooping poop and doing laundry and washing the dog dishes. That way we can keep an eye on the rascal. Then we put him up in the pen when we leave. We turn him loose for another hour or two in the afternoon when we head back for the evening chores. And he gets one more chance to run his steeplechase course when we let him out again for the final "pit stop" before bedtime.
Smokey, our little wobbler, loves being outside in the snow during the day -- it's soft enough that tumbling over in this stuff is kind of like landing on a pillow. (Smokey's brother Charlie is no longer with us. Sadly, we had to euthanize him last fall because of a progressive nervous system disorder that was unrelated to his cerebellar hypoplasia.) So while Smokey wobbles around in the snow, Travis gets to stay in the wobbler den. He doesn't think it's fair but then, as we tell him, who said life was fair?
We need the snow to melt about, oh, another foot before we can let this scamp have free rein again.