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Oakwood Healthcare, Inc.

National Labor Relations Board
348 NLRB No. 37 (2006)


Oakwood Heritage Hospital (Heritage) was a 257-bed, acute care hospital with 181 registered nurses (RNs) on staff. The RNs reported to an on-site nursing manager, clinical manager, or clinical supervisor. Some of the RNs served as charge nurses whose responsibility was to oversee specific patient care units and to assign various duties to other RNs, licensed practical nurses (LPNs), nursing assistants, technicians, and paramedics. Charge nurses could also monitor patients in a care unit, meet with physicians and patients’ family members to discuss care, and take on their own patient load. Heritage had 12 RNs who permanently served as charge nurses and had a rotation program for several other RNs who would temporarily serve as additional charge nurses. The rotation was either set by the RNs themselves or by other supervisors. Not all RNs were placed on the rotation by their own choosing or because they were assigned to other hospital departments. As part of a negotiation dispute, the National Labor Relations Board (NLRB) was asked to determine whether the charge nurses were “supervisors” and whether they should be included or excluded from a collective bargaining agreement.

Rule of Law


Holding and Reasoning (not provided.)

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