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The AHA today urged the National Labor Relations Board to withdraw a notice of proposed rulemaking regarding the standard for determining joint-employer status or, consistent with the board’s historical approach, exempt hospitals from compliance. 
 
“Critically, the National Labor Relations Board (NLRB) failed to properly investigate the particular economic and practical effects the proposed rule would have on hospitals and health systems,” AHA wrote. “Had it done so, it would have quickly become clear that the proposed rule would adversely impact an already over-burdened hospital field and create a collective bargaining quagmire that will harm hospitals, their patients, their employees, and the communities they serve. The NLRB’s failure to conduct this hospital-specific analysis requires withdrawal of the proposed rule for noncompliance with the Administrative Procedure Act. At a minimum, the NLRB must, consistent with decades of policy and practice, exempt hospitals from any final rule. Failure to do so risks compromising the hospital field and its very purpose: patient care.”
 
View the AHA letter for the association’s detailed comments.