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Expanded Use of Supplemental Nurses during the COVID-19 Pandemic (GAO-24-106447)

Summary

A GAO report to congressional addressees, GAO-24-106447, dated August 2024, on hospitals' use of supplemental nurses, meaning nurses temporarily contracted through external staffing agencies. GAO reports that use of supplemental nurses increased in the selected hospitals in its review during the COVID-19 pandemic. GAO requested data from 11 selected hospitals from 2019 to 2022, and six were able to provide complete data for those 4 years. The report describes how hospitals rely on nurses to meet patients' treatment and care needs and may contract supplemental staff when they lack enough employed staff.

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                United States Government Accountability Office
                Report to Congressional Addressees




                HOSPITALS
August 2024




                Expanded Use of
                Supplemental Nurses
                during the COVID-19
                Pandemic




GAO-24-106447
                                                August 2024

                                                HOSPITALS
                                                Expanded Use of Supplemental Nurses during the
                                                COVID-19 Pandemic
Highlights of GAO-24-106447, a report to
congressional addressees




Why GAO Did This Study                          What GAO Found
Hospitals are reliant on nurses, among          Use of supplemental nurses—nurses temporarily contracted by hospitals through
other clinicians and staff, to meet the         external staffing agencies—increased in the selected hospitals in GAO’s review
treatment and care needs of their               during the COVID-19 pandemic. Specifically, GAO requested data from 11
patients. When they do not have                 selected hospitals from 2019 to 2022. Of the six selected hospitals that were able
enough employed staff to provide care           to provide complete data for these 4 years, five of the hospitals reported that the
for their patients, they may contract           proportion of registered nurse (RN) hours worked by supplemental RNs more
with external staffing agencies for             than doubled. Overall use ranged from 2 to 28 percent in 2022 (see table).
supplemental nurses.
                                                Proportion of Supplemental Registered Nurse (RN) Use in Selected Hospitals, 2019 and 2022
The CARES Act includes a provision
for GAO to report on its ongoing                                  Hospital A         Hospital B          Hospital C        Hospital D          Hospital E       Hospital F
COVID-19 monitoring and oversight                 2019                      3%               <1%                 <1%                 4%                13%                8%
efforts. GAO was also asked to review             2022                      6%                 7%                 16%              12%                   2%             28%
hospitals’ use of supplemental nurses           Source: GAO analysis of data on supplemental RN hours or full-time equivalent employees provided by selected hospitals. | GAO-24-
                                                106447
during the COVID-19 pandemic. This
report describes (1) selected hospitals’        Data provided to GAO by the six selected hospitals also show the average hourly
use of supplemental nurses from 2019            cost of RNs increased from 2019 to 2022, with a greater rate of increase for
through 2022 and (2) selected                   supplemental RNs than for directly employed nurses. Specifically, the percentage
hospitals’ other strategies for                 increases for these six hospitals ranged from 14 to 45 percent for directly
responding to staffing challenges               employed RNs and from 53 to 266 percent for supplemental RNs. GAO found
during the pandemic.                            similar trends in use and average hourly cost in California hospital data.
GAO interviewed a nongeneralizable              Representatives GAO interviewed from 11 selected hospitals reported
sample of 11 acute care hospitals that          implementing a range of new and pre-existing strategies, to respond to staffing
represent a variety of locations, health        challenges in the COVID-19 pandemic (see figure). Nine of the 11 hospitals
system affiliations, ownership types,
                                                avoided reductions in operating capacity during the pandemic, representatives
and numbers of licensed beds. Six of
                                                told GAO. However, representatives from two of the hospitals reported
these hospitals were able to provide
GAO complete data for 2019 through              operational changes, such as closing a unit or reducing the number of beds
2022 on their use of, spending on, and          available for patients. Representatives from seven of the nine hospitals credited
average hourly cost of supplemental             their hospitals’ ability to maintain capacity, as the pandemic continued, to the
nursing staff. GAO also interviewed             increased use of supplemental nurses.
representatives from four health care
                                                Examples of Selected Hospitals’ Strategies for Responding to Staffing Shortages
staffing agencies selected based on
market size and seven academic
researchers with relevant expertise.
GAO also analyzed 2019-2022 data
from California hospitals on the use
and cost of nursing staff. GAO selected
California as it had publicly available
data for directly employed and
supplemental nursing staff. GAO also
analyzed data from national sample
surveys of RNs by the Health
Resources and Services
Administration in 2018 and 2022.

View GAO-24-106447. For more information,
contact Leslie V. Gordon at (202) 512-7114 or
GordonLV@gao.gov.
                                                                                                               United States Government Accountability Office
Contents


Letter                                                                                       1
               Background                                                                   4
               Use and Hourly Cost of Supplemental Nurses in Selected
                 Hospitals Increased during the COVID-19 Pandemic                           7
               Selected Hospitals Reported Using a Range of Strategies to
                 Address Staffing Challenges                                               15
               Agency Comments                                                             18

Appendix I     Information about Selected Hospitals                                        21



Appendix II    Information about California Hospitals                                      26



Appendix III   Information from National Sample Surveys of Licensed Registered
               Nurses in 2018 and 2022                                                     30



Appendix IV    Strategies Used by Selected Hospitals to Address Staffing Needs and
               Changes to the Strategies during the COVID-19 Pandemic              34



Appendix V     GAO Contact and Staff Acknowledgments                                       43


Tables
               Table 1: Supplemental Registered Nurse (RN) Use as a
                       Percentage of Total RN Use in Selected Hospitals, 2019
                       to 2022                                                              8
               Table 2: Spending on Supplemental Registered Nurse (RN) as a
                       Percentage of Total Hospital Spending on RNs in
                       Selected Hospitals, 2019 to 2022                                     9
               Table 3: Hours Worked by Type of Nursing Staff in California
                       Hospitals That Reported Supplemental Nursing Staff Use,
                       Fiscal Years 2019 to 2022                                           10
               Table 4: Percentage Change in Average Hourly Cost for
                       Registered Nurses (RN) in Selected Hospitals, from 2019
                       to 2022                                                             12



               Page i                         GAO-24-106447 Hospital Use of Supplemental Nurses
         Table 5: Average Hourly Cost for Nursing Staff Reported by
                 California Hospitals That Used Supplemental Nursing
                 Staff, Fiscal Years 2019 to 2022                                   14
         Table 6: Characteristics of Selected Hospitals                             21
         Table 7: Supplemental Registered Nurses (RN) Hours or Full-
                 Time Equivalent Employees (FTE) in Selected Hospitals,
                 2019 – 2022                                                        23
         Table 8: Spending on Supplemental Registered Nurses (RN) in
                 Selected Hospitals, 2019 – 2022                                    24
         Table 9: Average Hourly Cost for Registered Nurses (RN) in
                 Selected Hospitals, 2019 – 2022                                    24
         Table 10: Characteristics of California Short-term Acute Care
                 Hospitals That Reported Using Supplemental Nursing
                 Staff, Fiscal Year 2019 – 2022                                     27
         Table 11: Hours Worked by Nursing Staff in California Hospitals
                 That Reported Supplemental Nursing Staff Use, Annually,
                 Fiscal Year 2019 – 2022                                            29
         Table 12: Average Hourly Cost for Nursing Staff Reported by
                 California Hospitals That Reported Using Supplemental
                 Nursing Staff, Fiscal Year 2019 – 2022                             29
         Table 13: National Estimates of Licensed Registered Nurses (RN)
                 in Inpatient Hospital Settings, by Employment Type, 2017
                 and 2021                                                           32

Figure
         Figure 1: Selected Hospitals’ Reported Strategies for Responding
                  to Staffing Shortages                                             16




         Page ii                       GAO-24-106447 Hospital Use of Supplemental Nurses
Abbreviation

RN                registered nurse




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Page iii                               GAO-24-106447 Hospital Use of Supplemental Nurses
                       Letter




441 G St. N.W.
Washington, DC 20548




                       August 1, 2024

                       Congressional Addressees

                       Hospitals are reliant on nursing staff, along with other clinicians and
                       hospital staff, to meet the treatment and care needs of their patients.
                       When hospitals do not have enough employed staff to provide care for
                       their patients, they may contract with external staffing agencies for
                       temporary staff. This practice has been an important part of nurse staffing
                       for decades.

                       Surges in COVID-19 cases during periods of the pandemic, often
                       associated with the emergence of new variants, stressed hospitals with
                       high patient volumes. 1 It also depleted nursing staff and clinicians who
                       faced exposure to the virus as part of their jobs. The extended length of
                       the COVID-19 pandemic—over 3 years—placed further stress on
                       hospitals and their staff, leading to increased staff burnout, exhaustion,
                       and trauma.

                       Local and national news media reported that wages paid to contracted
                       temporary nursing staff, which we refer to as supplemental nurses,
                       jumped during the pandemic. Media reports indicated that wage
                       differences between nurses directly employed by hospitals and
                       supplemental nurses led to some nurses leaving direct hospital
                       employment in favor of contracts with staffing agencies. These reports




                       1The Secretary of Health and Human Services first declared the COVID-19 pandemic a
                       public health emergency under section 319 of the Public Health Service Act on January
                       30, 2020. In addition, on March 13, 2020, the President declared COVID-19 a national
                       emergency under the National Emergencies Act and a nationwide emergency under
                       section 501(b) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act
                       (Stafford Act). The national emergency declaration terminated on April 10, 2023, and the
                       Stafford Act declarations terminated on May 11, 2023, though the nation is still recovering
                       from the public health and economic effects of the pandemic.



                       Page 1                                 GAO-24-106447 Hospital Use of Supplemental Nurses
also highlighted the potential financial implications to hospitals due to the
increased need for, and cost of, supplemental nurses. 2

The CARES Act includes a provision for us to report on our ongoing
monitoring and oversight efforts related to the COVID-19 pandemic. 3
Further, you asked us to examine how hospitals’ use of supplemental
nurses changed during the pandemic.

This report describes (1) selected hospitals’ use of supplemental nurses
from 2019 through 2022, and (2) selected hospitals’ other strategies for
responding to staffing challenges during the COVID-19 pandemic.

To address both objectives, we interviewed representatives and
requested data from a nongeneralizable selection of 11 acute care
hospitals. 4 We selected the 11 hospitals to represent a variety of
locations, health system affiliations, ownership types, and numbers of
licensed beds. We cannot generalize our findings from the 11 hospitals to
other hospitals. (See appendix I for more information on our 11 selected
hospitals and how we selected them.)


2Nurses are a labor cost to hospitals. Unlike physicians and advanced practice registered
nurses, the care that nurses provide is not directly billed to insurance.

For examples of media reports, see Lenny Bernstein, “As COVID Persists, Nurses Are
Leaving Staff Jobs – and Tripling their Salaries as Travelers,” The Washington Post, Dec.
6, 2021; Leticia Miranda, “Rural Hospitals Losing Hundreds of Staff to High-Paid Traveling
Nurse Jobs,” NBC Business News, Sept. 15, 2021; Abby Vesoulis and Abigail Abrams,
“Contract Nurse Agencies Are Making Big Money in the Age of COVID-19. Are They
‘Exploiting’ the Pandemic?” TIME, Feb. 23, 2022; and Jessie Hellmann and Alex Kacik,
“Beyond the Byline: Providers Accuse Staffing Agencies of Price Gouging,” Modern
Healthcare, Mar. 17, 2022.
3Pub. L. No. 116-136, § 19010(b), 134 Stat. 281, 579 (2020). The American Rescue Plan
Act of 2021 also includes a provision for us to conduct oversight of the COVID-19
response. Pub. L. No. 117-2, § 4002, 135 Stat. 4, 78. All of GAO’s reports related to the
COVID-19 pandemic are available on GAO’s website at https://www.gao.gov/coronavirus.
Since 2020, we have reported on challenges hospitals experienced during the COVID-19
pandemic, including federal efforts to respond to them. See the following reports related to
hospital staffing challenges: (1) GAO, Public Health Preparedness: COVID-19 Medical
Surge Experiences and Related HHS Efforts, GAO-22-105461 (Washington, D.C.: Aug.
17, 2022); (2) GAO, Behavioral Health and COVID-19: Higher-Risk Populations and
Related Federal Relief Funding, GAO-22-104437 (Washington, D.C., Dec. 10, 2021); and
(3) GAO, COVID-19: Opportunities to improve Federal Response and Recovery Efforts,
GAO-20-625 (Washington, D.C.: Jun. 25, 2020).
4There are no comprehensive federal hospital nurse staffing data that distinguish between
directly employed and supplemental nursing staff.




Page 2                                  GAO-24-106447 Hospital Use of Supplemental Nurses
From the 11 selected hospitals, we requested data for 2019 through 2022
for both directly employed and supplemental nursing staff—including
registered nurses (RN), licensed vocational nurses, and certified nurse
assistants. 5 Six of the 11 hospitals were able to provide data for all 4
years requested. To address our first objective, we analyzed and reported
the following data from these six selected hospitals:

•   inpatient nurse use (reported in either inpatient nursing hours or
    inpatient nursing full-time equivalents),
•   total hospital spending, and
•   hourly cost paid by the hospital.
We limited our analysis to RNs because four of the six selected hospitals
did not report use of other supplemental nursing staff, such as licensed
vocational nurses and certified nursing assistants.

To provide additional context, we also identified and examined publicly
available data from California hospitals for 2019 through 2022 on the
annual use of and hourly cost for both directly employed and
supplemental nursing staff. 6 We examined California hospital data
because the data distinguished between directly employed and
supplemental nursing staff, which may include RNs, licensed vocational
nurses, and aides and orderlies. We limited our analysis of California
hospitals to short-term general acute care hospitals that reported a full
year of data, among other exclusions. (See appendix II for more
information on our analysis of data on California hospitals.) Our analysis
of California hospital data is not generalizable to other states.

We assessed the reliability of the data provided by our selected hospitals
by interviewing hospital representatives and reviewing the data to identify
any anomalies. We also assessed the reliability of the California data by
reviewing relevant data documentation, interviewing knowledgeable
officials, and performing tests of the data to identify any outliers or



5In this report, we use the term licensed vocational nurses, which includes both licensed
vocational nurses and licensed practical nurses. According to the U.S. Bureau of Labor
Statistics, these types of nurses have nearly identical responsibilities, but their titles vary
across states.
6Certain hospitals licensed by the California Department of Public Health must submit
annual financial disclosure reports. See Cal. Health and Safety Code § 128735 (2024).
These reports are compiled based on the end date of the fiscal year reported.




Page 3                                   GAO-24-106447 Hospital Use of Supplemental Nurses
                     anomalies. We determined that the data were sufficiently reliable for the
                     purposes of our reporting objectives.

                     To inform both objectives, we also reviewed documents and interviewed
                     three national stakeholder associations representing hospitals, staffing
                     agencies, and nurses; four health care staffing agencies selected based
                     on largest market size in 2021; and seven academic researchers with
                     expertise on hospital nurse staffing and use of supplemental nurses. For
                     example, in these interviews, we discussed the nurse staffing challenges
                     during the pandemic and the pandemic’s impact on hospital use of and
                     spending on supplemental nurses. We also interviewed officials from
                     relevant Department of Health and Human Services’ agencies, including
                     the Centers for Medicare & Medicaid Services, the Health Resources and
                     Services Administration, and the Office of the Assistant Secretary for
                     Planning and Evaluation.

                     We conducted this performance audit from December 2022 to August
                     2024 in accordance with generally accepted government auditing
                     standards. Those standards require that we plan and perform the audit to
                     obtain sufficient, appropriate evidence to provide a reasonable basis for
                     our findings and conclusions based on our audit objectives. We believe
                     that the evidence obtained provides a reasonable basis for our findings
                     and conclusions based on our audit objectives.

                     More than 1.8 million nurses worked in hospitals at the end of 2021.
Background           Nurses are critical to hospitals and have a direct effect on patient care.
                     They provide most patient assessments, evaluations, and physical care,
                     often attend to patients’ social and mental needs, and prepare patients
                     and their families to leave the hospital. Further, as patient care has
                     become more complex, nurses may need to make critical decisions
                     associated with care for sicker, frailer patients and help patients manage
                     chronic illnesses. When hospitals have temporary nurse vacancies, they
                     may contract for supplemental nurses through external staffing agencies
                     using a variety of different arrangements. Prior to the COVID-19
                     pandemic, use of supplemental nurses was a common hospital practice.
                     Hospitals have varying options in how they structure contracts with
                     external staffing agencies.

Supplemental Nurse   Health care staffing agencies hire nurses to fill temporary assignments
Arrangements         wherever nurses are needed. Supplemental nurses often work in
                     hospitals, but may also work in other settings, such as nursing homes.
                     The educational and licensing requirements and daily responsibilities of a
                     supplemental nurse are typically the same as a directly employed nurse.


                     Page 4                          GAO-24-106447 Hospital Use of Supplemental Nurses
                            A nurse may hold jobs through a staffing agency as a primary job,
                            secondary job, or both.

                            Staffing agencies offer a range of temporary assignment types for
                            supplemental nurses. Common arrangements include:

                            •   per diem (payment per day) arrangements, in which nurses work
                                locally and typically operate on a shift-by-shift basis,
                            •   travel arrangements, in which nurses fill temporary vacancies for a
                                contracted period of time. 7 The contract length for travel
                                arrangements is often 13 weeks, but it can vary depending on the
                                hospital’s needs.
                            Health care staffing agencies typically screen each nurse candidate for
                            the necessary training, licensure, and clinical competencies needed for
                            the client’s facility. Once a nurse’s contract begins, staffing agencies
                            typically provide their nurses with complete compensation packages
                            during their temporary assignments, which may include competitive
                            wages, professional liability insurance, retirement savings plans, and,
                            when travel is required, reimbursements for housing, meals, and travel
                            expenses, among other things.

Staffing Agency Contracts   In their arrangements with staffing agencies, hospitals can (1) manage
with Hospitals              one or more staffing agency contracts directly or (2) contract with a single
                            staffing agency to manage their supplemental nursing needs, known as a
                            managed service provider agreement. In such an arrangement, the
                            managed service provider typically uses a combination of nurses through
                            its own staffing agency and from other staffing agencies to fulfill the
                            hospital’s needs and manages that process for the hospital.

                            For hospitals part of larger health systems, the staffing agency contract
                            structure, and decisions about the need for supplemental nurses, can
                            vary. Specifically, some staffing agency contracts may be between the
                            agency and the health system, with decisions on the need for
                            supplemental nurses occurring either at the hospital- or health system-
                            level. Other contracts may be between the agency and the individual



                            7Health care staffing agencies may offer other types of contractual arrangements for
                            supplemental nurses and hospitals, such as rapid response arrangements (quick
                            responses to regional emergencies, such as natural disasters, in which a large number of
                            nurses are needed for a shorter period of time).




                            Page 5                                GAO-24-106447 Hospital Use of Supplemental Nurses
hospital, with decisions on the need for supplemental nurses occurring at
the hospital level.

A hospital’s contract with a staffing agency may vary in the amount of
support the agency provides the hospital with supplemental nurse
recruitment and hiring. For example, staffing agencies may conduct
interviews with nurse candidates and send the most qualified to the
hospital for selection or staffing agencies may provide all potential nurse
candidates to the hospital to interview and select.

Hospitals pay staffing agencies an hourly amount for each supplemental
nurse placed in the facility. The hourly amount includes more than just the
hourly pay rate to the supplemental nurse. The total hourly cost of the
supplemental nurse to the hospital, is made up of both the (1) nurse costs
(including, but not limited to, hourly pay rate, payroll taxes, and benefits)
and (2) operating expenses (the staffing agency’s overhead costs) and
staffing agency earnings. 8 In comparison, the hourly cost to the hospital
for a directly employed nurse includes the nurse’s hourly wages, benefits
(health insurance, retirement, paid time off), and payroll taxes. 9

Hospitals generally decide what they are willing to pay staffing agencies
for each supplemental nurse. Staffing agencies may provide hospitals
with market rate information to help in that determination. Further, once
placed in the hospital, day-to-day oversight of the supplemental nurse is
generally provided by the hospital’s on-site supervisor. Other
responsibilities are managed by the staffing agency, including payroll,
insurance and other benefits, and worker’s compensation, among other
things.




8A supplemental nurse’s hourly pay rate was the largest component of the bill rate (about
52 percent) in 2022, followed by housing and meal reimbursement (about 21 percent),
according to an industry report based on a survey of staffing agencies. See Staffing
Industry Analysts and National Association of Travel Healthcare Organizations’ Travel
Nurse Benchmarking Survey, Historical Trends Report: Survey Years 2018 through 2023
(Mountain View, CA: Staffing Industry Analysts, 2023).
9Hourly cost to the hospital for directly employed nurses does not include indirect costs,
such as recruiting costs and sign-on bonuses, among other costs.




Page 6                                 GAO-24-106447 Hospital Use of Supplemental Nurses
                             The use and cost of supplemental nurses increased in selected hospitals,
Use and Hourly Cost          as well as in California hospitals, from 2019 to 2022. Supplemental RN
of Supplemental              staffing as a percentage of total RN staffing in 2022 varied across the six
                             selected hospitals that provided data for all 4 years. The peak in use of,
Nurses in Selected           and average hourly cost for, supplemental nurses across the four years of
Hospitals Increased          data we analyzed occurred in the latter years of the pandemic (2021 or
                             2022) in both our selected hospitals and California hospitals. The average
during the COVID-19          hourly cost for nurses increased for all nursing types in our selected
Pandemic                     hospitals and for California hospitals, and the increase in average hourly
                             costs for supplemental nurses exceeded the increase in average hourly
                             costs for directly employed nurses.

Selected Hospitals’ Use of   The use of and spending on supplemental nurses—specifically RNs—in
Supplemental Nurses          the inpatient setting in most of our six selected hospitals increased during
                             the COVID-19 pandemic, especially in the pandemic’s later stages (2021
Increased during the
                             and 2022). We saw similar trends in California hospitals. National RN and
Pandemic, with the           employer survey data also show increases in RNs employed by staffing
Percentage of                agencies during the pandemic.
Supplemental Nurses to
Total Nurses Ranging from    Selected hospitals increased supplemental nurse use. Specifically,
                             five out of six selected hospitals that reported all 4 years of data (2019 to
2 to 28 in 2022              2022), reported increases in the use of supplemental RNs from 2019 to
                             2022. Data from the sixth hospital showed variation across the 4 years,
                             with an overall decrease in its use of supplemental nurses.

                             For example, one hospital reported 304 total hours for supplemental RNs
                             in 2019, which increased to 16,270 total hours in 2022. For directly
                             employed RNs, this hospital reported 230,935 total hours in 2019, which
                             decreased to 220,096 total hours in 2022. (See app. I.)

                             Supplemental RN staffing as a percentage of total RN staffing ranged
                             from less than 1 to 13 percent in 2019 and ranged from about 2 to 28
                             percent of total RN staffing in 2022, in our six hospitals. 10 (See table 1.)




                             10The proportion of supplemental RN staffing for one of these hospitals was about 28
                             percent in 2022, following no use of supplemental RN staff in 2020. Representatives noted
                             that the hospital relied more on supplemental staffing in 2021 and 2022 as it converted
                             into a regional medical center and recruited directly hired staff.




                             Page 7                                GAO-24-106447 Hospital Use of Supplemental Nurses
Table 1: Supplemental Registered Nurse (RN) Use as a Percentage of Total RN Use in Selected Hospitals, 2019 to 2022

                                             Hospitals’ supplemental RN staffing (reported as either hours worked by or
                                                full-time equivalent employees) as a percentage of total RN staffing                             Change
 Selected hospital                                                      2019                  2020                2021                    2022 2019 to 2022
 Hospital A                                                                  3                    4                    5                      6         ▲
 Hospital B                                                               <1a                     5                  10                       7         ▲
 Hospital C                                                               <1b                     0c                   3                     16         ▲
 Hospital D                                                                  4                    7                  12                      12         ▲
 Hospital Ed                                                               13                     3                  20                       2         ▼
 Hospital Fe                                                                 8                    0                  20                      28         ▲
▲ indicates an increase.
▼ indicates a decrease.
Source: GAO analysis of data provided by six of GAO’s selected hospitals. | GAO-24-106447

                                                                Note: Of the six hospitals that provided data for all 4 years, two hospitals reported data by hospital
                                                                fiscal year (defined as July 1 through June 30) and four hospitals reported by calendar year.
                                                                a
                                                                    This value was 0.1.
                                                                b
                                                                    This value was 0.5.
                                                                c
                                                                    This hospital used no supplemental RN staffing in 2020.
                                                                d
                                                                 Representatives told us they needed supplemental nurses due to major changes to their patient
                                                                census in 2021 during the pandemic. The hospital reduced use of supplemental nursing staff in 2022
                                                                because they were able to hire directly employed nurses.
                                                                e
                                                                 This hospital used no supplemental RN staffing in 2020, when the hospital had significantly reduced
                                                                hiring of directly employed staff in anticipation of a change in ownership. Representatives noted that
                                                                the hospital relied more on supplemental staffing in 2021 and 2022 as it converted into a regional
                                                                medical center and recruited directly hired staff.


                                                                In the five hospitals that reported increases in their use of supplemental
                                                                RNs, reported hospital spending on supplemental RNs increased from
                                                                2019 to 2022, and these increases in spending on supplemental RNs
                                                                outpaced the increases in their use. For example, one hospital’s spending
                                                                on supplemental RNs approximately quadrupled, increasing from
                                                                $2,310,411 in 2019 to $9,262,158 in 2022, while its use of supplemental
                                                                RNs doubled during the same period. For directly employed RNs, this
                                                                hospital reported spending $73,434,510 in 2019 and $85,136,777 in 2022
                                                                (an increase of nearly $12 million), while its use of directly employed RNs
                                                                stayed nearly the same. (See app. I.)

                                                                Five of the six hospitals that reported an increased use of supplemental
                                                                nurses also reported increased spending on supplemental RNs as a
                                                                proportion of their total spending. Hospital spending on supplemental RNs
                                                                as a percentage of total hospital spending on RNs grew to 50 percent or
                                                                more for two of the hospitals by 2022, with spending on supplemental




                                                                Page 8                                        GAO-24-106447 Hospital Use of Supplemental Nurses
                                                                nurses remaining under 20 percent of total spending on RNs for the other
                                                                four hospitals. (See table 2.)

Table 2: Spending on Supplemental Registered Nurses (RN) as a Percentage of Total Hospital Spending on RNs in Selected
Hospitals, 2019 to 2022

                                             Hospitals’ reported spending on supplemental RNs (as a percentage of total
                                                                           RN spending)                                                               Change
 Selected hospital                                                    2019                  2020                 2021                    2022       2019 to 2022
 Hospital A                                                                3                   4                     5                      10            ▲
 Hospital B                                                             <1a                    8                    20                      12            ▲
 Hospital C                                                                2                  0b                    16                      67            ▲
 Hospital D                                                                5                  11                    22                      18            ▲
 Hospital E                                                              20                    5                    32                       4            ▼
 Hospital F                                                              12                   0b                    44                      50            ▲
▲ indicates an increase.
▼ indicates a decrease.
Source: GAO analysis of data provided by six of GAO’s selected hospitals. | GAO-24-106447

                                                                Note: Two of the six hospitals reported data by hospital fiscal year (defined as July 1 through June
                                                                30) and four of the hospitals reported by calendar year.
                                                                a
                                                                 This value was 0.2.
                                                                b
                                                                 Hospitals C and F used no supplemental RN staffing in 2020.


                                                                All six selected hospitals reported that their use of and spending on
                                                                supplemental RNs peaked during later stages of the COVID-19
                                                                pandemic—2021 or 2022—rather than in the first year. The use of
                                                                supplemental RNs as a percentage of total RN use and spending on
                                                                supplemental RNs as a percentage of total hospital spending also
                                                                increased. For example, data reported by two hospitals showed the
                                                                highest proportion of use and spending in 2021, and the other three
                                                                hospitals showed the highest proportion of use and spending in 2022.
                                                                The remaining hospital showed its highest proportion of use in 2021,
                                                                which remained the same in 2022. Representatives from one of the
                                                                hospitals attributed this to staff beginning to fall ill in 2021 and pandemic-
                                                                related turnover in nurses increasing in 2022. The hospital’s issues with
                                                                turnover did not begin until the end of 2021, leading into 2022, and
                                                                coincided with a 15 percent increase in patient volume. (See app. I for
                                                                additional information on RN use and spending over time in selected
                                                                hospitals.)

                                                                California hospitals also show increase in use of supplemental
                                                                nurse staffing. Similar to our selected hospitals, we found California
                                                                hospitals also reported increases in their use of supplemental nursing



                                                                Page 9                                      GAO-24-106447 Hospital Use of Supplemental Nurses
                                                                 staff during the COVID-19 pandemic. (For the California hospitals, these
                                                                 increases in supplemental nursing staff use may have included increased
                                                                 use of RNs, licensed vocational nurses, and aides and orderlies, unlike
                                                                 for our selected hospitals where we report on supplemental RN use
                                                                 specifically.) Most California hospitals (about 92 percent each year)
                                                                 reported using supplemental nursing staff; the average total hours worked
                                                                 by supplemental nursing staff in these hospitals increased from about
                                                                 29,000 hours in fiscal year 2019 to about 42,000 hours in fiscal year 2022
                                                                 (a 45 percent increase). See appendix II for more information.

                                                                 Overall use of supplemental nursing staff in California hospitals as a
                                                                 percentage of total nurse staff remained under 10 percent in 2022.
                                                                 Specifically, for California hospitals reporting the use of supplemental
                                                                 nurses, the average proportion of annual hours worked by supplemental
                                                                 nursing staff increased from fiscal year 2019 to fiscal year 2022. The
                                                                 average proportion of annual hours worked by directly employed RNs
                                                                 increased, while the proportion of annual hours worked by other directly
                                                                 employed nursing staff decreased. (See table 3.)

Table 3: Hours Worked by Type of Nursing Staff in California Hospitals That Reported Supplemental Nursing Staff Use, Fiscal
Years 2019 to 2022

                                                                     Average Percentage of Annual Hours Worked by Each Type of
                                                                    Nursing Staff of Total Nurse Staffing Hours in California Hospitals
                                                                           Fiscal year               Fiscal year               Fiscal year             Fiscal year
                                                                                 2019                      2020                      2021                    2022      Change
 Type of nursing staff                                                        (n=243)                   (n=238)                   (n=238)                 (n=236)    2019 to 2022
 Directly               Registered nurses                                               71                        72                        72                 72         ▲
 employed               Licensed vocational nurses                                        6                         5                         5                 4         ▼
 nursing staff
                        Aides and orderlies                                             20                        20                        20                 19         ▼
 Supplemental nursing staffa                                                              5                         5                         5                 7         ▲
▲ indicates an increase.
▼ indicates a decrease.
Source: GAO analysis of California Department of Health Care Access and Information, Hospital Annual Financial and Utilization data. | GAO-24-106447

                                                                 Notes: We limited our analysis to short-term general and short-term children’s acute care hospitals
                                                                 that reported a full year of data. Totals are from all hospital inpatient units in these hospitals, which
                                                                 may include non-acute care units.
                                                                 We excluded 31 Kaiser hospitals from our analysis that did not report average hourly cost for all 4
                                                                 years in our review.
                                                                 Totals in columns do not add to 100 percent due to rounding.
                                                                 a
                                                                  In this report, we refer to the state’s category of registry nursing personnel (which may include
                                                                 registered nurses, licensed vocational nurses, and aides and orderlies) as supplemental nursing staff.


                                                                 National survey data also showed increases in RNs employed by
                                                                 staffing agencies. National survey data estimates indicated similar


                                                                 Page 10                                                 GAO-24-106447 Hospital Use of Supplemental Nurses
                         trends. Specifically, data from a sample survey of RNs conducted by the
                         Health Resources and Services Administration within the Department of
                         Health and Human Services showed that the number of hospital RNs
                         employed by staffing agencies increased during the pandemic.
                         Approximately 2 percent of the estimated 1.17 million RNs whose primary
                         job was in an inpatient hospital setting were employed by a staffing
                         agency in 2017, compared with approximately 10 percent of the
                         estimated 1.27 million RNs working in an inpatient hospital setting in
                         2021. (See app. III for more information.) Additionally, data from a sample
                         survey of employers conducted by the U.S. Bureau of Labor Statistics
                         showed that the estimated percentage of employees working as RNs for
                         external staffing agencies in any sector of the economy (including, but not
                         limited to, the health care sector) increased during the pandemic, with
                         about 2 percent of RNs working for external staffing agencies in 2019 and
                         about 3 percent in 2022. 11

Nurse Hourly Costs       Data we collected from six selected hospitals show average hourly cost
Increased for Selected   for both directly employed RNs and supplemental RNs increased from
                         2019 to 2022, with a greater rate of increase for supplemental RNs. 12
Hospitals during the
                         Specifically, of the six selected hospitals that reported all 4 years of data,
Pandemic, with Greater   all hospitals reported increases in average hourly cost for RNs from 2019
Rates of Increase for    to 2022. The percentage increase ranged from about 14 to 45 percent for
Supplemental Nurses      directly employed RNs and from about 53 to 266 percent for
                         supplemental RNs. (See table 4.)




                         11The U.S. Bureau of Labor Statistics’ Occupational Employment and Wage Statistics
                         program produces employment and wage estimates for approximately 830 occupations
                         based on a survey of business establishments (employers). Data are published annually
                         with a May reference date and each year’s estimates were produced by a model-based
                         estimation method using three years of data. See U.S. Bureau of Labor Statistics’ “All May
                         2022 Data,” Occupation Employment and Wage Statistics Tables, accessed June 7, 2024,
                         and “All May 2019 Data,” Occupation Employment and Wage Statistics Tables, accessed
                         Jan. 9, 2024, https://www.bls.gov/oes/tables.htm.
                         12The hourly cost to the hospital for a directly employed nurse includes the nurse’s hourly
                         wages, benefits, and payroll taxes. The hourly cost to the hospital for a supplemental
                         nurse is the rate paid to the staffing agency. This rate includes both the nurse costs
                         (including hourly pay rate, payroll taxes, and benefits) and operating expenses (the
                         staffing agency’s overhead costs) and earnings.




                         Page 11                                GAO-24-106447 Hospital Use of Supplemental Nurses
Table 4: Percentage Change in Average Hourly Cost for Registered Nurses (RN) in Selected Hospitals, from 2019 to 2022

                          Directly employed RNs average                                           Supplemental RNs average hourly
                              hourly cost (in dollars)                                                   cost (in dollars)
 Hospital                          2019                       2022          Change (percent)                   2019                  2022        Change (percent)
 Hospital A                      $76.49                    $94.94                           24%             $76.61               $143.82                         88%
 Hospital B                      $46.24                    $62.12                           34%             $76.02               $116.31                         53%
 Hospital C                      $30.00                    $40.25                           34%             $41.00               $150.00                        266%
 Hospital D                      $35.59                    $40.55                           14%             $57.35                 $93.14                        62%
 Hospital E                      $43.18                    $50.17                           16%             $71.80               $123.18                         72%
 Hospital F                      $36.26                    $52.58                           45%             $58.28               $131.76                        126%
Source: GAO analysis of data provided by six of GAO’s selected hospitals. | GAO-24-106447

                                                                Notes: Two of the six hospitals reported data by hospital fiscal year (defined as July 1 through June
                                                                30) and four of the hospitals reported by calendar year.
                                                                The hourly cost to the hospital for a directly employed nurse includes the nurse’s hourly wages,
                                                                benefits, and payroll taxes. The hourly cost to the hospital for a supplemental nurse is the rate paid to
                                                                the staffing agency. This rate includes both the nurse costs (including hourly pay rate, payroll taxes,
                                                                and benefits) and operating expenses (the staffing agency’s overhead costs) and earnings.


                                                                According to representatives from three of the six hospitals, hourly costs
                                                                for supplemental RNs were trending down and stabilizing as of the time
                                                                we conducted the interviews, which was after the federal government
                                                                ended the COVID-19 public health emergency declaration in May 2023. 13
                                                                For example, representatives at one of the hospitals noted declining costs
                                                                for supplemental nurses as of September 2023, but stated that they did
                                                                not anticipate that supplemental nurse payment rates would ever return to
                                                                pre-pandemic levels. Representatives at another one of the hospitals
                                                                echoed this, describing higher payment rates for supplemental nurses as
                                                                the “new normal.”

                                                                According to representatives from most of the selected hospitals and
                                                                staffing agencies we interviewed, hospitals or their health systems decide
                                                                what total hourly amount they are able or willing to pay staffing agencies
                                                                for each supplemental nurse. The supplemental nurse’s hourly payment
                                                                rate and benefits make up a large portion of the total cost, but other
                                                                components, such as staffing agency overhead and earnings, also
                                                                contribute. For example, representatives from one hospital noted that
                                                                their managed service provider furnishes market reports on supplemental

                                                                13Representatives from two additional selected hospitals and two selected staffing
                                                                agencies also described decreasing payment rates to supplemental RNs at the time we
                                                                conducted interviews in mid-2023. Specifically, we conducted interviews with hospital and
                                                                staffing agency representatives from June through October 2023.




                                                                Page 12                                      GAO-24-106447 Hospital Use of Supplemental Nurses
                                                            nurse payment rates and supplemental nurse payments the hospital is
                                                            making, which the hospital executives use to discuss ways to reduce
                                                            costs.

                                                            Representatives from two hospitals said the cost of supplemental nurses
                                                            increased because they were competing with hospitals across the nation.
                                                            For example, representatives at one hospital said the high sign-on
                                                            bonuses and rates paid to supplemental nurses did not increase the
                                                            number of available nurses in the workforce. Rather, representatives
                                                            explained, the increased compensation created incentives for nurses to
                                                            leave the hospital’s direct employment and work as supplemental nurses
                                                            elsewhere. The representatives said this movement of nurses around the
                                                            country made the hospital’s workforce less stable and managing it took
                                                            hospital staff time and energy away from caring for patients.
                                                            Representatives from one staffing agency also noted the shift to
                                                            nationwide competition for nurses. These representatives said as the
                                                            entire country began experiencing COVID-19 surges (rather than in
                                                            isolated geographic regions), competition for supplemental nurses
                                                            became national. They explained this shift allowed nurses the opportunity
                                                            to pursue the highest payment rate and often prompted hospitals to offer
                                                            payment rates above the highest existing rate.

Example of a Staffing Agency’s Gross                        Hospital representatives we spoke with raised concerns about the profits
Profit and Margins                                          retained by external staffing agencies, while staffing agencies we spoke
AMN Healthcare is a publicly traded health                  with told us that their profit margins declined during the pandemic.
care staffing agency and, as such, it releases
annual financial reports. From 2019 through
                                                            Specifically, representatives we interviewed from three hospitals said that
2022, AMN reported increases in its gross                   the increases in the hospitals’ hourly payments to staffing agencies were
profits, but a decrease in its gross margin.                not passed on to supplemental nurses as increases in their hourly wages.
Specifically, AMN’s gross profits increased
from $743.5 million in 2019 to $1,716.7 million
in 2022 and its gross margins decreased from                Also, the American Hospital Association reported that the margin retained
about 34 percent in 2019 to about 33 percent
in 2022.                                                    by staffing agencies increased during the pandemic from an average of
AMN also reported gross margin for its nurse                about 15 percent in 2019 to an average of about 62 percent in January
and allied health professionals (such as                    2022. 14 In contrast, an analysis by Staffing Industry Analysts and The
physical therapists and lab technicians)
segment specifically, with gross margins                    National Association of Travel Healthcare Organizations reported that
decreasing from about 28 percent in 2019 to                 staffing agencies’ gross margin percentage decreased from about 26
about 26 in 2022.
Source: GAO review of AMN Healthcare financial reports. |
GAO-24-106447




                                                            14See The American Hospital Association, Massive Growth in Expenses and Rising
                                                            Inflation Fuel Continued Financial Challenges for America’s Hospitals and Health Systems
                                                            (Washington, D.C.: The American Hospital Association, 2022).




                                                            Page 13                              GAO-24-106447 Hospital Use of Supplemental Nurses
                                                                 percent in 2018 to 23 percent in 2022. 15 Staffing agency representatives
                                                                 attributed the large increase in prices to the spike in demand for a finite
                                                                 number of nurses. In addition, representatives from one agency noted
                                                                 that the staffing agency market was not concentrated enough for
                                                                 individual agencies to affect prices and that states with rate caps in place
                                                                 waived them during the pandemic because those hospitals could not
                                                                 attract supplemental nurses.

                                                                 Similar to what we found in the data provided by our six selected
                                                                 hospitals, California hospitals also reported increases in the average
                                                                 hourly cost paid for all nursing staff during the pandemic, with the rate of
                                                                 increase in the cost for supplemental nursing staff exceeding the rate of
                                                                 increase in cost for directly employed nurses. Of the California hospitals
                                                                 that used supplemental nursing staff,

                                                                 •     the total average hourly cost for directly employed RNs increased by
                                                                       about 10 percent, increasing from $58.70 in fiscal year 2019 to $64.70
                                                                       in fiscal year 2022.
                                                                 •     the total average hourly cost for supplemental nursing staff increased
                                                                       by about 62 percent, increasing from $81.40 in fiscal year 2019 to
                                                                       $131.50 in fiscal year 2022. (See table 5.)

Table 5: Average Hourly Cost for Nursing Staff Reported by California Hospitals That Used Supplemental Nursing Staff, Fiscal
Years 2019 to 2022

                                                                                                  Average hourly cost (in dollars)
 Type of nursing staff                                                                          Fiscal year 2019                  Fiscal year 2022        Change (percent)
 Directly employed                        Registered nurses                                                    $58.70                            $64.70               10%
 nursing staff                            Licensed vocational nurses                                           $32.00                            $34.60                8%
                                          Aides and orderlies                                                  $21.80                            $24.40               12%
 Supplemental nursing staffa                                                                                   $81.40                          $131.50                62%
Source: GAO analysis of California Department of Health Care Access and Information, Hospital Annual Financial and Utilization data. | GAO-24-106447

                                                                 Notes: We limited our analysis to short-term general and short-term children’s hospitals that reported
                                                                 a full year of data. Totals are from all hospital units in these hospitals, which may include non-acute
                                                                 care units.
                                                                 We excluded 31 Kaiser hospitals from our analysis that did not report staffing data for all 4 years in
                                                                 our review.



                                                                 15Gross margin is the hourly rate the staffing agencies charge for a supplemental nurse,
                                                                 minus the total cost of sales, which includes licensing and medical benefits for the
                                                                 supplemental nurse. See Staffing Industry Analysts and National Association of Travel
                                                                 Healthcare Organizations’ Travel Nurse Benchmarking Survey, Historical Trends Report:
                                                                 Survey Years 2018 through 2023 (Mountain View, CA: Staffing Industry Analysts, 2023).




                                                                 Page 14                                                 GAO-24-106447 Hospital Use of Supplemental Nurses
                      a
                       In this report, we refer to the state’s category of registry nursing personnel (which may include
                      registered nurses, licensed vocational nurses, and aides and orderlies) as supplemental nursing staff.


                      The 11 selected hospitals we interviewed for this review reported
Selected Hospitals    implementing a range of strategies to respond to staffing challenges in
Reported Using a      the COVID-19 pandemic. Specifically, representatives from the 11
                      selected hospitals described using nine types of new and pre-pandemic
Range of Strategies   staffing strategies to address the increased and more complex nurse
to Address Staffing   staffing needs of the pandemic. We categorized these nine strategies into
                      four broader categories—hospital use of its directly employed nurses,
Challenges            hospital use of health system nurses, other hospital staffing strategies,
                      and hospital use of staffing agencies. See figure 1 below for a description
                      of each staffing strategy and appendix IV for more detailed information on
                      how selected hospitals used each strategy, including changes during the
                      pandemic.




                      Page 15                                    GAO-24-106447 Hospital Use of Supplemental Nurses
Figure 1: Selected Hospitals’ Reported Strategies for Responding to Staffing Shortages




                                         Representatives from five hospitals described that they prioritized starting
                                         with their own directly employed nurses before moving to supplemental
                                         nurses when filling immediate staffing needs. For example,
                                         representatives from one hospital described first trying to fill staffing
                                         needs with their own nurses through financial incentives for extra shifts or
                                         the use of nurses from the hospital’s own float pool (a group of nurses



                                         Page 16                            GAO-24-106447 Hospital Use of Supplemental Nurses
who float across separate units within a single hospital), then bringing in
nurses from other hospitals in the health system, when applicable, before
contracting with supplemental nurses through external staffing agencies.

While facing staffing challenges during the pandemic, representatives
from nine of the 11 selected hospitals reported they were able to avoid
reductions in available beds or unit closures, aside from operating room
closures early in the pandemic. 16 Representatives at seven of these nine
hospitals credited their hospital’s ability to maintain capacity to the
increased use of supplemental nurses. For example, representatives from
one hospital stated that without the help of supplemental nurses, the
hospital’s operating capacity and ability to care for patients would have
been diminished.

In contrast, representatives from two selected hospitals stated that the
hospitals struggled to meet staffing needs using the strategies discussed
above, and as a result, had to make operational changes.

•   One of the two hospitals closed its acute rehabilitation unit during the
    pandemic, which hospital representatives attributed to the high cost of
    both supplemental nurses and directly employed nurses. 17
•   Representatives from the other hospital stated that shortages in
    nurses reduced the number of beds the hospital could make available
    to patients, particularly at the beginning of the pandemic. According to
    hospital representatives, the hospital’s owners at that time decided
    not to replace any nurses that left, which led the hospital to decrease

16Nine selected hospitals reported temporarily closing operating rooms or significantly
limiting operating room capacity early in the pandemic. Hospital representatives indicated
that these changes were often in response to certain state orders or recommended by
some state hospital associations.
While none of our selected hospitals described furloughing or laying off nurses during the
COVID-19 pandemic, representatives of a stakeholder organization and a few researchers
we spoke with noted that many hospitals furloughed staff at the beginning of the pandemic
when elective surgeries were put on hold. According to survey data, almost a quarter of
the RN workforce experienced some form of employer-driven employment disruption
during the pandemic, including forced leave, furloughs (with or without pay), and layoffs.
See Department of Health and Human Services’ Health Resources and Services
Administration, National Center for Health Workforce Analysis, Experience of Nurses
Working During the COVID Pandemic – Data from the 2022 National Sample Survey of
RNs (March 2024).
17Hospital representatives noted that the acute rehabilitation unit was still closed at the
time of our interview in August 2023. Representatives explained that as the hospital hired
new nurses, it continued to assess whether to reopen the unit.




Page 17                                 GAO-24-106447 Hospital Use of Supplemental Nurses
                      its capacity and transfer patients to hospitals outside of the immediate
                      area. Representatives explained that the hospital changed owners in
                      late 2020, and there was a shift in philosophy and hiring practices.
                      The new owners increased their staffing levels through use of
                      supplemental nurses while they converted the hospital into a regional
                      medical center.
                  During the pandemic, some of the hospitals in our review also made other
                  operational changes in response to the increase in patient volume and
                  the change in patient needs. Specifically, representatives from five
                  hospitals reported they opened new units or converted existing units to
                  care for COVID-19 patients. Representatives from four hospitals also
                  reported stopping new admissions when they reached capacity or being
                  unable to transfer patients to other facilities in the region. For example,
                  representatives from one hospital reported that they opened a second
                  intensive care unit when they were not able to transfer patients who
                  needed a higher level of care, such as a heart bypass machine.

                  We provided a draft of this report to the Department of Health and Human
Agency Comments   Services for review and comment. The Department provided technical
                  comments, which we incorporated as appropriate.

                  We are sending copies of this report to the appropriate congressional
                  committees, the Secretary of Health and Human Services, and other
                  interested parties. In addition, the report is available at no charge on the
                  GAO website at http://www.gao.gov.

                  If you or your staff have any questions about this report, please contact
                  me at (202) 512-7114 or at GordonLV@gao.gov. Contact points for our
                  Offices of Congressional Relations and Public Affairs may be found on
                  the last page of this report. GAO staff who made key contributions to this
                  report are listed in Appendix V.




                  Leslie V. Gordon
                  Director, Health Care




                  Page 18                          GAO-24-106447 Hospital Use of Supplemental Nurses
List of Addressees

The Honorable Patty Murray
Chair
The Honorable Susan Collins
Vice Chair
Committee on Appropriations
United States Senate

The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate

The Honorable Bernie Sanders
Chair
The Honorable Bill Cassidy, M.D.
Ranking Member
Committee on Health, Education, Labor and Pensions
United States Senate

The Honorable Gary C. Peters
Chairman
The Honorable Rand Paul, M.D.
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Tom Cole
Chairman
The Honorable Rosa L. DeLauro
Ranking Member
Committee on Appropriations
House of Representatives

The Honorable Cathy McMorris Rodgers
Chair
The Honorable Frank Pallone, Jr.
Ranking Member
Committee on Energy and Commerce
House of Representatives


Page 19                       GAO-24-106447 Hospital Use of Supplemental Nurses
The Honorable Mark E. Green, M.D.
Chairman
The Honorable Bennie G. Thompson
Ranking Member
Committee on Homeland Security
House of Representatives

The Honorable James Comer
Chairman
The Honorable Jamie Raskin
Ranking Member
Committee on Oversight and Accountability
House of Representatives

The Honorable Jason Smith
Chairman
The Honorable Richard Neal
Ranking Member
Committee on Ways and Means
House of Representatives

The Honorable Tracey Mann
House of Representatives




Page 20                      GAO-24-106447 Hospital Use of Supplemental Nurses
Appendix I: Information about Selected
              Appendix I: Information about Selected
              Hospitals


Hospitals

              In order to describe hospitals’ use of supplemental nurses from 2019
              through 2022, we interviewed representatives from a nongeneralizable
              selection of 11 acute care hospitals. To select these hospitals, we used
              data from the Centers for Medicare & Medicaid Services to take a random
              sample of 121 of the 4,860 hospitals located in the 50 states and the
              District of Columbia as of December 2022. The hospitals in our sample
              included short-term acute care hospitals, critical access hospitals, and
              children’s hospitals. 1

              We removed hospitals with hiring and staffing models that likely differed
              significantly from general acute care hospitals. These included hospitals
              owned and operated by the Department of Veterans Affairs, the Indian
              Health Service, and the Department of Defense, as well as specialty
              hospitals, emergency department-only hospitals, and outpatient-only
              facilities. Removing these hospitals resulted in a final sample of 108
              hospitals.

              We then reached out to the 93 hospitals for which we could find contact
              information to request an interview. Representatives from 11 hospitals
              accepted our invitation for interviews from July through October 2023. We
              cannot generalize our findings from the 11 hospitals to other hospitals.

              The 11 hospitals we interviewed represent a variety of locations, health
              system affiliations, ownership types, and numbers of licensed beds. (See
              table 6.)

              Table 6: Characteristics of Selected Hospitals

              Characteristic                           Number of selected hospitals (n = 11)
              Hospital type                            •  Short-term general acute care hospital: 10
                                                       •  Critical access hospital: 1
                                                       •  Children’s hospital: 0
              Census region                            •  Northeast: 3
                                                       •  South: 4
                                                       •  Midwest: 4
                                                       •  West: 0



              1All other types of hospitals and other provider types were excluded. To select the random
              samples, we used the publicly available Centers for Medicare & Medicaid Services’
              December 2022 Provider of Services file, accessed on March 23, 2023, from
              https://data.cms.gov/provider-characteristics/hospitals-and-other-facilities/provider-of-
              services-file-hospital-non-hospital-facilities.




              Page 21                                  GAO-24-106447 Hospital Use of Supplemental Nurses
Appendix I: Information about Selected
Hospitals




 Characteristic                                      Number of selected hospitals (n = 11)
 Location type                                       •     Urban: 5
                                                     •     Rural: 6
 Health system affiliation                           •     Yes: 8
                                                     •     No: 3
 Ownership type                                      •     For-profit: 1
                                                     •     Nonprofit: 8
                                                     •     State government: 2
                                                     •     Other: 0
 Number of licensed inpatient beds                   •     100 beds or less: 4
 reported by the hospital during our                 •     101-250 beds: 5
 data collection (July to November
                                                     •     More than 250 beds: 2
 2023)
Source: GAO summary of interviews with and data submitted by 11 selected hospitals. | GAO-24-106447

Note: Our random sample of 121 hospitals, from which we interviewed the 11 hospitals, included
short-term acute care hospitals, critical access hospitals, and children’s hospitals. None of the 11
hospitals that agreed to an interview were children’s hospitals.


Data requested from selected hospitals. We requested data from the
11 selected hospitals on use of, spending on, and hourly cost for directly
employed and supplemental nurses. We requested data from 2019
through 2022. Of the nine hospitals providing data, six provided data for
all 4 years, and three were able to provide data for 1 or 2 years. 2 We
reported data for the six hospitals that were able to provide data for all 4
years requested. These six hospitals reported minimal use of
supplemental licensed vocational nurses or supplemental certified nurse
aides, so we limited our analysis to registered nurses (RN). To analyze
each hospital’s

•     use of supplemental nurses, we used data hospitals provided on
      inpatient nursing hours or inpatient nursing full-time equivalents for all
      directly employed nursing staff and all supplemental nursing staff. 3
      This included information on the totals for all nurses (registered
      nurses, licensed vocational nurses, and certified nurse aides), as well
      as totals specifically for RNs.

2Three hospitals were able to provide data for 1 or 2 years. These hospitals were each
acquired by a different health system during our period of review and were unable to
provide data for years under the prior ownership, according to representatives from these
hospitals. The other two hospitals did not provide us with the requested data.
3Our data request directed hospitals to indicate whether they were reporting inpatient

nursing hours or inpatient nursing full-time equivalents. Of the six hospitals that provided
all 4 years of data, four reported inpatient nursing hours and two reported inpatient nursing
full-time equivalents.




Page 22                                               GAO-24-106447 Hospital Use of Supplemental Nurses
                                         Appendix I: Information about Selected
                                         Hospitals




                                         •   spending on inpatient nurse staffing, we used data hospitals provided
                                             on total spending for all directly employed nurse staff and directly
                                             employed RNs, as well as all supplemental nurse staff and
                                             supplemental RNs, specifically. 4
                                         •   average hourly cost for inpatient nurse staff, we used data hospitals
                                             provided on all directly employed nurses and supplemental nurses
                                             (RN, licensed vocational nurses, and certified nurse aides), as well as
                                             specifically for RNs. 5
                                         Hospitals indicated whether they were reporting by fiscal year or calendar
                                         year. Of the six hospitals that provided all 4 years of data, two reported by
                                         fiscal year and four reported by calendar year. Both hospitals’ fiscal years
                                         were July 1 through June 30. 6

                                         Additional information on use of and spending on RNs in selected
                                         hospitals. The use of, and spending on, supplemental RNs peaked later
                                         in the COVID-19 pandemic, with three of the selected hospitals showing a
                                         peak in 2021, and the other three hospitals showing a peak in 2022. (See
                                         tables 7 and 8.)

Table 7: Supplemental Registered Nurse (RN) Hours or Full-Time Equivalent Employees (FTE) in Selected Hospitals, 2019 –
2022

                                      Directly employed RNs                                     Supplemental RNs
                               2019          2020           2021        2022           2019         2020          2021        2022
Reported in FTEs
Hospital A                      476           469            462         478              15           18           22           31
Hospital D                      451           407            360         349              20           32           49           48
Reported in hours
Hospital B                  230,935      226,063        206,839      220,096            304       12,711        21,904      16,270
Hospital C                  149,696      147,512        145,958      138,229            782            0a        4,436      25,710



                                         4Our data request directed hospitals to include, in spending on inpatient nurse staffing, the

                                         wages and salaries and benefits for directly employed nurses, and staffing agency costs
                                         for supplemental nursing staff. We directed hospitals not to include spending on hiring and
                                         retention efforts for directly employed nurses.
                                         5Our data request directed hospitals to include, in their average hourly cost of inpatient
                                         nursing, the wages and salaries and benefits for directly employed nurses, and staffing
                                         agency costs for supplemental nursing staff. We directed hospitals not to include spending
                                         on hiring and retention efforts for directly employed nurses.
                                         6The three hospitals that provided data for 1 or 2 years, reported by fiscal year (July 1
                                         through June 30). The remaining two hospitals did not provide data.




                                         Page 23                                  GAO-24-106447 Hospital Use of Supplemental Nurses
                                                                Appendix I: Information about Selected
                                                                Hospitals




                                                          Directly employed RNs                                                  Supplemental RNs
                                                 2019                2020                   2021          2022         2019         2020             2021       2022
 Hospital E                                   17,028                18,997             17,807         20,665           2,492         606            4,569        386
 Hospital F                                   68,120                64,418             79,574         72,547           5,983             0a        19,119     28,647
Source: GAO analysis of data provided by six of GAO’s selected hospitals. | GAO-24-106447

                                                                Note: Two of the six hospitals reported data by hospital fiscal year (defined as July 1 through June
                                                                30) and four of the hospitals reported by calendar year.
                                                                a
                                                                 Hospitals C and F did not use any supplemental RNs in 2020.



Table 8: Spending on Supplemental Registered Nurses (RN) in Selected Hospitals, 2019 – 2022
Dollars

                                              Directly employed RNs                                                            Supplemental RNs
                                 2019                 2020                  2021                   2022            2019          2020              2021          2022
 Hospital A             73,434,510           75,048,541             77,856,409              85,136,777       2,310,411     2,900,708           4,451,109     9,262,158
 Hospital B             10,677,874           10,974,998             10,482,416              13,672,610            23,073       963,911         2,635,296     1,892,373
 Hospital C               7,022,300            7,232,504             6,177,073               2,715,910           115,008            0a         1,184,965     5,542,664
 Hospital D             43,600,000           42,700,000             39,900,000              41,700,000       2,400,000     5,300,000          11,100,000     9,300,000
 Hospital E                  735,311              985,197            1,000,577               1,036,659           178,911        53,256          463,122        47,548
 Hospital F               2,470,292            2,556,276             3,407,177               3,814,395           348,708            0a         2,618,042     3,774,470
Source: GAO analysis of data provided by six of GAO’s selected hospitals. | GAO-24-106447

                                                                Note: Two of the six hospitals reported data by hospital fiscal year (defined as July 1 through June
                                                                30) and four of the hospitals reported by calendar year.
                                                                a
                                                                 Hospitals C and F did not use any supplemental RNs in 2020.


                                                                Additionally, average hourly costs for directly employed RNs and
                                                                supplemental RNs generally increased from 2019 to 2022, with the
                                                                average hourly cost for supplemental RNs seeing a greater increase.
                                                                (See table 9.)

Table 9: Average Hourly Cost for Registered Nurses (RN) in Selected Hospitals, 2019 – 2022

Dollars

                                                        Directly employed RNs                                                   Supplemental RNs
                                              2019                  2020              2021           2022              2019          2020             2021       2022
 Hospital A                                  76.49                  79.95            85.57           94.94            76.61         77.99            99.23     143.82
 Hospital B                                  46.24                  48.55            50.68           62.12            76.02         75.84           120.31     116.31
 Hospital C                                  30.00                  31.50            35.00           40.25            41.00              0a          70.00     150.00
 Hospital D                                  35.59                  37.82            37.77           40.55            57.35         79.51           108.50      93.14
 Hospital E                                  43.18                  51.86            56.19           50.17            71.80         87.82           101.37     123.18




                                                                Page 24                                           GAO-24-106447 Hospital Use of Supplemental Nurses
                                                                Appendix I: Information about Selected
                                                                Hospitals




                                                        Directly employed RNs                                                Supplemental RNs
                                              2019                  2020              2021       2022              2019            2020            2021          2022
 Hospital F                                  36.26                  39.68            42.82      52.58             58.28               0a         136.93        131.76
Source: GAO analysis of data provided by six of GAO’s selected hospitals. | GAO-24-106447

                                                                Notes: Two of the six hospitals reported data by hospital fiscal year (defined as July 1 through June
                                                                30) and four of the hospitals reported by calendar year.
                                                                The hourly cost to the hospital for a directly employed nurse includes the nurse’s hourly wages,
                                                                benefits, and payroll taxes. The hourly cost to the hospital for a supplemental nurse is the rate paid to
                                                                the staffing agency. This rate includes both the nurse costs (including hourly pay rate, payroll taxes,
                                                                and benefits) and operating expenses (the staffing agency’s overhead costs) and earnings.
                                                                a
                                                                 Hospitals C and F did not use any supplemental RNs in 2020.




                                                                Page 25                                      GAO-24-106447 Hospital Use of Supplemental Nurses
Appendix II: Information about California
               Appendix II: Information about California
               Hospitals


Hospitals

               In order to describe hospitals’ use of supplemental nurses from 2019
               through 2022, we identified and examined available data from California
               hospitals that distinguished between directly employed and supplemental
               nursing staff. Specifically, we examined 2019 through 2022 data from
               hospital annual financial disclosure reports compiled based on the end of
               the fiscal year reported and publicly available from California’s
               Department of Health Care Access and Information (California officials). 1
               We limited our analysis to acute care hospitals, including short-term
               general or short-term children’s hospitals that reported a full year of data,
               and excluded any hospitals that did not provide emergency services. 2

               We also excluded hospitals that did not report using supplemental nursing
               staff in a given year, and 31 Kaiser hospitals that reported data on the
               average hourly cost for the latter two years of our time period (fiscal years
               2021 and 2022), but not in the first two years (fiscal years 2019 and
               2020). 3 Following these exclusions, the number of California acute care
               hospitals that reported data for fiscal years 2019 through 2022 were 243,
               238, 238, and 236, respectively. Our analysis of California hospital data is
               not generalizable to other states. In particular, California hospitals may
               1Certain hospitals licensed by the California Department of Public Health must submit
               these reports. See Cal. Health and Safety Code § 128735 (2024). California officials told
               us that the data are self-reported and self-certified using an electronic system. While
               California officials conduct a desk audit on these reports—during which they check for
               reasonableness and comparability—before the data are made publicly available, it is
               possible that hospitals might not complete certain parts of the report.
               These data were downloaded from https://data.chhs.ca.gov/dataset/hospital-annual-
               financial-disclosure-report-complete-data-set in April and October 2023. These data
               represent point-in-time snapshots of California hospital staffing.

               Hospitals’ fiscal years may vary. These reports were grouped by fiscal years ending from
               June 30, 2018, through June 29, 2019, as fiscal year 2019; June 30, 2019, through June
               29, 2020, as fiscal year 2020; June 30, 2020, through June 29, 2021, as fiscal year 2021;
               and June 30, 2021, through June 29, 2022, as fiscal year 2022.
               2We excluded hospitals that were identified in the data set as short- and long-term
               psychiatric care, short- and long-term specialty care, long-term general care, and long-
               term children’s care. We also excluded hospitals for fiscal years where they did not report
               any registered nurse hours, or where they reported less than a year of data, which may be
               due to situations including changes in ownership or licensure.
               3Most California hospitals (about 92 to 93 percent each fiscal year) reported using
               supplemental nurses.

               Some California hospitals, including Kaiser hospitals, are not required to submit full annual
               reports, either by law or when a reporting modification has been granted, primarily when
               the data to be reported are not comparable to data filed by other hospitals. California
               officials told us that, until 2021, Kaiser hospitals had a long-time exemption from reporting
               some revenue data.




               Page 26                                 GAO-24-106447 Hospital Use of Supplemental Nurses
                                                                 Appendix II: Information about California
                                                                 Hospitals




                                                                 differ from hospitals in other states due to California’s mandatory
                                                                 minimum nurse-to-patient staffing ratios that began in 2004. 4

                                                                 To understand the population of California hospitals in our analysis, we
                                                                 examined descriptive information on available facility characteristics. A
                                                                 majority of the hospitals were owned by a non-profit or church-based
                                                                 organization and almost half of the hospitals had more than 250 licensed
                                                                 beds. (See table 10.)

Table 10: Characteristics of California Short-term Acute Care Hospitals That Reported Using Supplemental Nursing Staff,
Fiscal Year 2019 – 2022

Number (percentage)

                                                                     Fiscal year 2019                 Fiscal year 2020                Fiscal year 2021           Fiscal year 2022
                                                                             (n = 243)                        (n = 238)                       (n = 238)                  (n = 236)
 Type of ownership
 Church/Nonprofit                                                                 148 (61)                         146 (61)                        146 (61)              147 (62)
 Investor                                                                          58 (24)                          57 (24)                            57 (24)            57 (24)
 County or local government                                                        37 (15)                          35 (15)                            35 (15)            32 (14)
 Licensed inpatient beds
 100 beds or less                                                                  40 (17)                          37 (16)                            37 (16)            37 (16)
 101 to 250 beds                                                                   98 (40)                          98 (41)                            92 (39)            92 (39)
 More than 250 beds                                                               105 (43)                        103 (43)                         109 (46)              107 (45)
Source: GAO analysis of California Department of Health Care Access and Information, Hospital Annual Financial and Utilization data. | GAO-24-106447

                                                                 Notes: We limited our analysis to short-term general and short-term children’s acute care hospitals
                                                                 that reported a full year of data. Totals are from all hospital inpatient units in these hospitals, which
                                                                 may include non-acute care units.
                                                                 We excluded 31 Kaiser hospitals from our analysis that did not report staffing data for all 4 years in
                                                                 our review.


                                                                 Variables of analysis. To analyze changes in

                                                                 •      the use of supplemental nurses across the 4 years from the California
                                                                        hospital data, we used data on nursing staff hours reported. For
                                                                        directly employed nursing staff hours, we used the variable
                                                                        “productive hours” for registered nurses (RN), licensed vocational
                                                                        nurses, and aides and orderlies, which are each reported separately.

                                                                 4According to one researcher we interviewed who studies health care workforce trends in
                                                                 California, the heavily unionized environment differentiates California from other states
                                                                 and may reduce nurses’ incentives to become supplemental nurses. Specifically, the
                                                                 researcher noted that there is a general perception of higher wages for directly employed
                                                                 hospital nurses and better hospital working conditions, such as nurse-to-patient ratios in
                                                                 California than in other regions of the country.




                                                                 Page 27                                                  GAO-24-106447 Hospital Use of Supplemental Nurses
Appendix II: Information about California
Hospitals




    For supplemental nursing staff hours, we used the variable “contract
    hours,” which combines any reported hours for supplemental RNs,
    licensed vocational nurses, and aides and orderlies into a single
    variable. 5
•   nurse hourly costs, we used the variable “average hourly rate.” As
    with the prior variables, rates for directly employed RNs, licensed
    vocational nurses, and aides and orderlies are each reported
    separately. Rates for supplemental nurses combine any reported
    hourly rates for supplemental RNs, licensed vocational nurses, and
    aides and orderlies into a single variable.
We were not able to examine changes in California hospital spending on
supplemental nurses because the state does not collect these data.

In our report, we present the mean value (or average), which may mask
variation among hospitals. Some hospitals in our sample may report
higher values and some may report lower values—of hours worked, and
average hourly costs. As a result, the increase or decrease in use and
hourly cost of nurses from 2019 through 2022 for some hospitals may be
greater than or lower than the average values we present.

Additional information on California hospitals’ use of supplemental
nurses. Among California hospitals reporting the use of supplemental
nursing staff—which may have included RNs, licensed vocational nurses,
and aides and orderlies—average annual hours decreased from 2019 to
2020 and increased from 2020 to 2022. 6 (See table 11.) Additionally, the
average hourly cost for all types of nursing staff increased from 2019 to
2022, with the average hourly cost for supplemental nursing staff seeing a
greater increase than for directly employed nursing staff. (See table 12.)




5In this report, we refer to the state’s category of registry nursing personnel (which may
include RNs, licensed vocational nurses, and aides and orderlies) as supplemental
nursing staff.
6The types of supplemental nurses are not broken out for hospitals.




Page 28                                 GAO-24-106447 Hospital Use of Supplemental Nurses
                                                                 Appendix II: Information about California
                                                                 Hospitals




Table 11: Hours Worked by Nursing Staff in California Hospitals That Reported Supplemental Nursing Staff Use, Annually,
Fiscal Years 2019 – 2022

                                                                                                     Annual average hours worked
 Type of nursing staff                                              Fiscal year 2019              Fiscal year 2020                Fiscal year 2021           Fiscal year 2022
 Directly employed nursing staff                                                 655,688                        671,221                        732,453               707,887
 Registered nurses                                                               504,676                        517,982                        569,856               554,411
 Licensed vocational nurses                                                        28,097                        25,039                          25,866               21,588
 Aides and orderlies                                                             136,511                        141,369                        149,409               140,817
 Supplemental nursing staffa                                                       28,866                        27,719                          31,823               41,966
Source: GAO analysis of California Department of Health Care Access and Information, Hospital Annual Financial and Utilization data. | GAO-24-106447

                                                                 Notes: We limited our analysis to short-term general and short-term children’s acute care hospitals
                                                                 that reported a full year of data. Totals are from all hospital inpatient units in these hospitals, which
                                                                 may include non-acute care units. About 92 to 93 percent of these hospitals reported hours for
                                                                 supplemental nursing staff.
                                                                 We excluded 31 Kaiser hospitals from our analysis that did not report staffing data for all 4 years in
                                                                 our review.
                                                                 a
                                                                  In this report, we refer to the state’s category of registry nursing personnel (which may include
                                                                 registered nurses, licensed vocational nurses, and aides and orderlies) as supplemental nursing staff.



Table 12: Average Hourly Cost for Nursing Staff Reported by California Hospitals That Reported Using Supplemental Nursing
Staff, Fiscal Years 2019 – 2022

Dollars

                                                                                                 Fiscal year              Fiscal year              Fiscal year      Fiscal year
 Type of nursing staff                                                                                 2019                     2020                     2021             2022
 Directly employed                   Registered nurses                                                   58.70                     60.70                  59.10           64.70
 nursing staff                       Licensed vocational nurses                                          32.00                     32.80                  32.50           34.60
                                     Aides and orderlies                                                 21.80                     22.60                  22.10           24.40
 Supplemental nursing staffa                                                                             81.40                     84.10                  91.90         131.50
Source: GAO analysis of California Department of Health Care Access and Information, Hospital Annual Financial and Utilization data. | GAO-24-106447

                                                                 Notes: We limited our analysis to short-term general and short-term children’s acute care hospitals
                                                                 that reported a full year of data. Totals are from all hospital inpatient units in these hospitals, which
                                                                 may include non-acute care units.
                                                                 We excluded 31 Kaiser hospitals from our analysis that did not report staffing data for all 4 years in
                                                                 our review.
                                                                 The hourly cost to the hospital for a directly employed nurse includes the nurse’s hourly wages,
                                                                 benefits, and payroll taxes. The hourly cost to the hospital for a supplemental nurse is the rate paid to
                                                                 the staffing agency. This rate includes both the nurse costs (including hourly pay rate, payroll taxes,
                                                                 and benefits) and operating expenses (the staffing agency’s overhead costs) and earnings.
                                                                 a
                                                                  In this report, we refer to the state’s category of registry nursing personnel (which may include
                                                                 registered nurses, licensed vocational nurses, and aides and orderlies) as supplemental nursing staff.




                                                                 Page 29                                                 GAO-24-106447 Hospital Use of Supplemental Nurses
Appendix III: Information from National
              Appendix III: Information from National Sample
              Surveys of Licensed Registered Nurses in


Sample Surveys of Licensed Registered
              2018 and 2022




Nurses in 2018 and 2022
              To describe the number of nurses working as supplemental nurses in
              hospitals prior to and during the COVID-19 pandemic, we analyzed
              publicly available data from two sample surveys of registered nurses (RN)
              collected by the Department of Health and Human Services’ Health
              Resources and Services Administration in 2018 and 2022, the two most
              recent surveys at the time of our analysis. 1

              The data from the 2018 survey included a weighted study sample of an
              estimated 2.99 million licensed nurses (RNs and advanced practice RNs
              working in primary positions requiring RN licenses), of which about 1.17
              million (about 39 percent) reported working in the hospital inpatient
              setting as of December 31, 2017. The data from the 2022 survey included
              a weighted study sample of an estimated 3.12 million licensed nurses, of
              which about 1.27 million (about 41 percent) reported working in the
              hospital inpatient setting as of December 31, 2021. 2

              We then analyzed data for the primary nursing position for RNs employed
              in a hospital inpatient setting, including those employed by a staffing
              agency. 3 We also analyzed how many RNs were employed by a staffing
              agency in their secondary nursing position, if applicable. 4 Comparisons
              between years are statistically significant at the 95 percent confidence
              interval unless otherwise noted. 5


              1See U.S. Department of Health and Human Services’ Health Resources and Services
              Administration’s 2018 National Sample Survey of Registered Nurses, accessed on June 6,
              2023, and 2022 National Sample Survey of Registered Nurses, accessed on March 22,
              2024, https://data.hrsa.gov/topics/health-workforce/nursing-workforce-survey-data. The
              two independent surveys provide point-in-time estimates. The National Sample Survey of
              RNs is not a longitudinal survey and does not track panels of the same nurses over time.
              2To be consistent with the standard applied by the Department of Health and Human
              Services’ Health Resources and Services Administration to ensure the statistical reliability
              of the estimates the agency presents of its survey data, all estimates we report have
              percent relative standard errors of less than 30 percent unless otherwise noted.
              3The survey instructions categorized acute inpatient units, the emergency department,
              and other non-acute hospital units, including hospital-sponsored outpatient clinics, urgent
              care, and ancillary units, in its hospital employment setting type, but excluded other
              inpatient settings, such as mental health hospitals and nursing homes not located within a
              hospital. Our report focuses on inpatient units within the hospital setting type.
              4Data on RNs working as supplemental nurses in secondary nursing jobs are not available
              by setting and may include RNs working in hospitals, other inpatient settings, ambulatory
              settings, or other settings.
              5Statistical significance at the 95 percent level means that there is a 5 percent probability
              or less of the differences between estimated values being due to chance alone.




              Page 30                                 GAO-24-106447 Hospital Use of Supplemental Nurses
Appendix III: Information from National Sample
Surveys of Licensed Registered Nurses in
2018 and 2022




We assessed the reliability of these data by reviewing relevant agency
data documentation, interviewing knowledgeable agency officials, and
performing tests of the data to identify any outliers or anomalies. We
determined that the data were sufficiently reliable for the purposes of our
reporting objectives.

The percentage of hospital RNs working for staffing agencies increased
more than four times during the COVID-19 pandemic, according to
national survey data estimates. Specifically, approximately 2 percent of
the estimated 1.17 million RNs whose primary position were in inpatient
hospital settings were employed by staffing agencies in 2017 compared
to approximately 10 percent of the estimated 1.27 million RNs working in
inpatient hospital settings in 2021. 6 (See table 13.) These data likely
underestimate the total number of RNs working as supplemental nurses
in inpatient hospital settings as, according to the survey results, many
RNs also held secondary positions as supplemental nurses. However, the
estimates of RNs’ secondary positions as supplemental nurses were not
available by setting, so it was not possible to determine the total number
of RNs working as supplemental nurses in inpatient hospital settings in
those years. 7




6While most supplemental hospital RNs worked in inpatient settings (about 82 percent in
2021), supplemental RNs also worked in the emergency department (about 12 percent in
2021) and other hospital settings, such as hospital-sponsored ambulatory or outpatient
care and hospital-sponsored ancillary units (about 6 percent in 2021).
7RNs may be simultaneously employed in another, secondary, nursing position for pay.
The number of supplemental RN positions filled at hospitals would include RNs working in
primary positions as well as RNs working in secondary positions through staffing
agencies. In 2017, about 1 percent of the estimated 2.99 million RNs working in a primary
nursing job, regardless of setting, also worked one or more secondary jobs as a
supplemental nurse employed by a staffing agency. In 2021, about 1 percent of the
estimated 3.12 million RNs working in a primary job, regardless of setting, also worked
one or more secondary jobs as a supplemental nurse employed by a staffing agency.




Page 31                                GAO-24-106447 Hospital Use of Supplemental Nurses
                                                               Appendix III: Information from National Sample
                                                               Surveys of Licensed Registered Nurses in
                                                               2018 and 2022




Table 13: National Estimates of Licensed Registered Nurses (RN) in Inpatient Hospital Settings, by Employment Type, 2017
and 2021

                                                                                       December 31, 2017                                         December 31, 2021
                                                                                     Estimated                    Estimated                     Estimated                   Estimated
 Employment situation                                                                  number                    percentage                       number                   percentage
 Employed by the hospital at which the RN worked                                      1,131,959                               97                 1,135,175                              89
 Employed by a staffing agency                                                             28,190                               2                  129,570                              10
 Self-employed                                                                               6,715                              1                           —                            —
 Total                                                                                1,166,865                             100                  1,272,584                             100
“— “ indicates that data were suppressed to ensure statistical reliability because the percent relative standard error was greater than 30 percent.
Source: GAO analysis of the Department of Health and Human Services’ Health Resources and Services Administration, 2018 National Sample Survey of RNs and 2022 National Sample Survey of RNs.
| GAO-24-106447

                                                               Notes: This analysis was based on weighted study samples of RNs and advanced practice RNs
                                                               working in a primary position requiring an RN license.
                                                               All reported estimates have percent relative standard errors of less than 30 percent, except as noted.
                                                               We calculated the 95 percent confidence interval for each estimated percentage and examined
                                                               whether there was overlap between confidence intervals. The confidence intervals did not overlap
                                                               between 2017 and 2021 for RNs employed by the hospital at which they worked or for RNs employed
                                                               by a staffing agency, which suggests a statistically significant difference between estimates.


                                                               Researchers we interviewed, as well as representatives from a nursing
                                                               stakeholder organization, discussed how the COVID-19 pandemic
                                                               intensified the hospital work environment for nurses. For example,
                                                               interviewees discussed concerns about nurse burnout, with stakeholder
                                                               representatives and one researcher noting that nurses experienced
                                                               higher levels of and more frequent feelings of burnout during the
                                                               pandemic. 8 In addition, interviewees said that nurses experienced
                                                               increases in workplace violence related to patients’ and families’ anger
                                                               regarding pandemic restrictions. At the same time, researchers and
                                                               stakeholder representatives noted that nurses’ trust in the hospitals
                                                               employing them was eroding. These interviewees said that some
                                                               hospitals were putting nurses into vulnerable situations, including the
                                                               following:

                                                               •     sometimes being the only type of clinician going into COVID-19-
                                                                     positive patients’ rooms,

                                                               8According to survey data, most RNs (about 89 percent of RNs who had been employed
                                                               in the same position for at least a year and had experienced burnout) indicated that their
                                                               feelings of burnout had increased during the pandemic. In addition, the report indicated
                                                               that feelings of burnout became more frequent during the pandemic. See U.S. Department
                                                               of Health and Human Services’ Health Resources and Services Administration, National
                                                               Center for Health Workforce Analysis, Experience of Nurses Working During the COVID
                                                               Pandemic – Data from the 2022 National Sample Survey of RNs (March 2024).




                                                               Page 32                                               GAO-24-106447 Hospital Use of Supplemental Nurses
Appendix III: Information from National Sample
Surveys of Licensed Registered Nurses in
2018 and 2022




•   working multiple shifts in a row without sufficient rest,
•   stretching nurse-to-patient ratios to potentially unsafe levels.
Researchers and stakeholder representatives we interviewed noted that
these types of work environment issues likely pushed some nurses to
leave the hospital setting or to leave the profession altogether. 9 It also
may have made travelling as a supplemental nurse appealing to more
nurses due to both the higher pay and the contractual relationship with
the hospital.




9According to survey data, about 9 percent of RNs employed left their employer for
another nursing job. In addition, about 5 percent of the RN workforce left the workforce
altogether during the pandemic, most commonly due to working conditions, such as high-
risk conditions, overwork or burnout, and inadequate staffing levels. See Health
Resources and Services Administration, Experience of Nurses Working During the COVID
Pandemic.




Page 33                                GAO-24-106447 Hospital Use of Supplemental Nurses
Appendix IV: Strategies Used by Selected
                           Appendix IV: Strategies Used by Selected
                           Hospitals to Address Staffing Needs and

Hospitals to Address Staffing Needs and
                           Changes to the Strategies during the COVID-19
                           Pandemic


Changes to the Strategies during the COVID-
19 Pandemic
                           Representatives at the 11 selected hospitals we interviewed described
                           using nine types of new and pre-pandemic staffing strategies to address
                           the increased and more complex nurse staffing needs of the COVID-19
                           pandemic. We categorized these nine strategies into four broader
                           categories—use of directly employed nurses, use of health system
                           nurses, other staffing strategies, and use of supplemental nurses.

Use of Directly Employed   Selected hospitals described three staffing strategies that used their own
Nurses                     directly employed nurses to meet staffing needs—shift-based financial
                           incentives, temporary nurse reassignment, and single hospital float pools.

                           Shift-based financial incentives. To meet staffing needs, hospitals may
                           provide shift-based financial incentives to its nurses within a unit.
                           Representatives from 10 of the 11 selected hospitals discussed using this
                           strategy. For example, one hospital paid nurses who worked an extra shift
                           in their unit a $300 bonus for the pay period and another hospital paid
                           nurses an extra $35 per hour when working one extra shift a week.
                           Further, representatives from one hospital described extending financial
                           incentives to nurses in supervisory roles, such as nurse directors, by
                           offering bonuses to cover shifts providing patient care.

                           Representatives from one of these ten hospitals specifically noted that the
                           hospital implemented this strategy in response to the COVID-19
                           pandemic—creating a program that paid premium rates to nurses who
                           worked additional shifts. However, representatives from three other
                           hospitals described how this strategy was less effective during the
                           pandemic. For example, representatives from one hospital explained that
                           prior to the pandemic, if they offered an incentivized overtime shift, it
                           would draw volunteers. These same representatives recounted that
                           during the pandemic they could not rely on the financial incentives to
                           draw volunteers for overtime shifts. These representatives noted that
                           nurse staff seemed to prioritize their time over the extra money, which
                           was beneficial for the hospital’s workforce but made meeting their staffing
                           needs more challenging. In addition, representatives at two hospitals
                           opined that their nurses became less likely to respond to financial
                           incentives for additional shifts during the pandemic, due to exhaustion
                           and burnout.




                           Page 34                               GAO-24-106447 Hospital Use of Supplemental Nurses
Appendix IV: Strategies Used by Selected
Hospitals to Address Staffing Needs and
Changes to the Strategies during the COVID-19
Pandemic




Temporary nurse reassignment. Hospitals may temporarily reassign
nurses that typically work in a specific unit to a different unit or reassign
non-clinical nurses to work at the patient bedside, as appropriate.
Representatives from nine of the 11 selected hospitals reported using this
strategy when needed. Three of these nine hospitals described having
this policy in place prior to the pandemic. Specifically, representatives
from one of the hospitals stated that it was their hospital’s expectation
that nurses work in any unit that needed assistance, as appropriate, and
the hospital offered its nurses cross-training for other units and
specialties. Representatives from another hospital noted that, due to the
hospital’s small size, they expected nurses to move between like units or
units where they have been cross-trained.

Six of these nine hospitals began temporarily reassigning nurses and two
of the three hospitals that already had this strategy in place expanded
their use of it to meet staffing needs during the COVID-19 pandemic.
Representatives from these hospitals described two ways in which they
used this strategy:

•   During non-essential operating room closures early in the pandemic
    (in response to certain state orders or recommended by some state
    hospital associations), some hospitals temporarily reassigned their
    operating room nurses to other units. For example, representatives
    from one hospital noted that when reassigning operating room nurses
    to the intensive care unit, those nurses were not functioning as
    intensive care unit nurses, but they were able to use their
    competencies to assist the nurse team.
•   Some hospitals temporarily reassigned non-clinical nurses or nurse
    leaders to the patient bedside when needed. For example,
    representatives from one hospital said certain times during the
    pandemic required creative staffing and an “all hands on deck”
    approach that included moving nurse coordinators and nurse
    administrators to the patient bedside. Representatives from another
    hospital described providing non-clinical nurses with a “crash course”
    orientation early in the pandemic so that they could assist intensive
    care unit nurses at the patient bedside.




Page 35                               GAO-24-106447 Hospital Use of Supplemental Nurses
                       Appendix IV: Strategies Used by Selected
                       Hospitals to Address Staffing Needs and
                       Changes to the Strategies during the COVID-19
                       Pandemic




                       Single hospital float pool. A single hospital float pool operates at the
                       individual hospital level by employing a group of nurses to “float,” or
                       move, between multiple units within a specialty or who are cross-trained
                       and oriented to float to multiple different specialty units. Representatives
                       from eight of the 11 selected hospitals discussed using this strategy.
                       Nearly all of the eight hospitals had their single hospital float pools in
                       place prior to the start of the pandemic, and representatives from a few of
                       the eight hospitals indicated that single hospital float pool nurses were
                       paid more than nurses not in the float pool.

                       In response to COVID-19 pandemic staffing challenges, one of the eight
                       hospitals created a single hospital float pool, and another hospital
                       expanded its existing program:

                       •   Representatives from the hospital that created a single hospital float
                           pool did so later in the pandemic by cross-training some of their
                           nurses to work in three separate units—the medical-surgical unit, the
                           intensive care unit, and the emergency department—and then paying
                           those float nurses an additional $15 per hour.
                       •   Representatives from another hospital described expanding their
                           hospital’s float pool by adding a new part-time option to make it more
                           attractive to the hospital’s nurses.

Use of Health System   Selected hospitals described two staffing strategies that use nurses from
Nurses                 other hospitals within its health system to meet staffing needs—multi-
                       hospital float pools and internal staffing agencies.

                       Multi-hospital float pool. A multi-hospital float pool operates across
                       hospitals within a defined geographical region, and within the same health
                       system, by employing a group of nurses to float to whichever hospital
                       they are needed for a given shift. These nurses are typically cross-trained
                       and oriented to float to multiple different specialty units as well.
                       Representatives from six of the eight selected hospitals that were part of
                       a health system discussed using this strategy. For example,
                       representatives at one hospital noted that nurses in the multi-hospital float
                       pool received an additional $7 to $9 to their hourly base pay.
                       Representatives at another hospital noted while the nurses they bring in
                       from the multi-hospital float pool may not be familiar with their specific
                       hospital, the nurses still worked under their health system. The
                       representatives added that this alignment of nurse expectations across
                       the health system made using this strategy to meet staffing needs more




                       Page 36                               GAO-24-106447 Hospital Use of Supplemental Nurses
Appendix IV: Strategies Used by Selected
Hospitals to Address Staffing Needs and
Changes to the Strategies during the COVID-19
Pandemic




desirable than contracting with supplemental nurses from external staffing
agencies.

At the time of our interviews, two of the six hospitals were working with
their health systems to develop multi-hospital float pools. While
representatives at both hospitals discussed informally using float nurses
from other nearby health system hospitals during the COVID-19
pandemic, they were in the process of formalizing the programs. For
instance, representatives from one of the hospitals noted that nurses in
this program would float between three hospitals and earn a $20 per hour
premium to their hourly payment rate.

Internal staffing agency. An internal staffing agency operates within a
health system and employs nurses to travel between system hospitals for
assigned periods of time, such as 4 weeks, before moving to the next
assignment at another hospital. These nurses are typically cross-trained
and oriented to float to multiple different specialty units as well.
Representatives from two of the eight selected hospitals that were part of
a health system discussed using this strategy to meet their staffing
needs. 1 They both compared their internal staffing agencies to the
services provided by external staffing agencies and noted that
participating nurses received premium pay similar to supplemental nurses
from external agencies. However, they also both explained that the
hospital and the health system were able to save money by eliminating
the external staffing agency and its fees.

The health system of one of the two hospitals using internal staffing
agencies created its program during the COVID-19 pandemic in response
to staffing and cost demands. Specifically, hospital representatives stated
that their internal travel program launched in January 2022, which
coincided with a surge in COVID-19 cases, and, by the end of 2022, the
hospital was using more internal agency staffing than external agency
staffing. The representatives noted that nurses working for their internal
staffing agency receive benefits and pay rates comparable with
supplemental nurses, and the representatives reported saving 20 percent




1Representatives from one of the three selected hospitals that was not part of a health
system described creating an internal supplemental staffing program in 2023 as an
alternative to using supplemental nurses from external staffing agencies. Since the
hospital was not part of a health system, representatives noted that the internal
supplemental staff were usually from other organizations in the local area.




Page 37                                GAO-24-106447 Hospital Use of Supplemental Nurses
                            Appendix IV: Strategies Used by Selected
                            Hospitals to Address Staffing Needs and
                            Changes to the Strategies during the COVID-19
                            Pandemic




                            or more by running the program internally rather than using external
                            staffing agencies.

Other Staffing Strategies   Selected hospitals described three other types of staffing strategies that
                            they used to meet staffing needs—nurse retention efforts, nurse
                            recruitment efforts, and changes to nursing care delivery models.

                            Nurse retention efforts. To encourage nurse retention, hospitals may
                            implement various types of programs, incentives, benefits, or pay
                            increases to directly employed nurses. 2 Representatives from 10 of the
                            11 hospitals discussed using this strategy to meet their staffing needs.
                            Representatives at four selected hospitals noted that their nurse payment
                            rates and benefits packages have been competitive, even prior to the
                            pandemic. For example, representatives from two hospitals noted that
                            they periodically conduct market reviews of nurse payment rates and
                            make payment adjustments, as appropriate, and representatives from the
                            two other hospitals noted that higher education benefits were key to
                            encouraging retention.

                            In response to COVID-19 pandemic staffing challenges, most of the 10
                            hospitals made changes or added to their retention efforts.

                            •   A few hospitals provided retention bonuses to their directly employed
                                nurses. For instance, representatives at one hospital explained that
                                they chose to financially reward their staff who stayed with the
                                hospital rather than direct that money toward recruitment.
                                Representatives from another hospital noted that they used COVID-
                                19-related state funds to provide qualifying staff with pandemic
                                bonuses. Further, representatives from several hospitals noted
                                increasing pay rates for directly employed nurses during the
                                pandemic.
                            •   A few hospitals developed new employee benefits or programs
                                intended to increase retention. For example, one hospital rolled out an
                                employee wellness program during the pandemic, which included
                                dedicating certain spaces for employee breaks, and a new virtual
                                mental health platform benefit available to both employees and their
                                families. Representatives from another hospital reported that they
                                accelerated their plans to open an on-site childcare center for
                                employees during the pandemic. Further, a third hospital focused on

                            2In response to a question on whether COVID-19 vaccine mandates during the pandemic
                            affected selected hospitals’ ability to retain or hire nurses, representatives from all 11
                            selected hospitals said that the mandates had little or no effect.




                            Page 38                                  GAO-24-106447 Hospital Use of Supplemental Nurses
Appendix IV: Strategies Used by Selected
Hospitals to Address Staffing Needs and
Changes to the Strategies during the COVID-19
Pandemic




    reducing first-year nurse turnover by developing a nurse residency
    program—a year-long program for newly-graduated nurses hired by
    the hospital. Representatives noted that the program focuses on
    providing participants with both peer and mentor support.
Nurse recruitment efforts. Hospitals may offer competitive
compensation packages, financial incentives, or programs at the time of
hiring to recruit new nurses or develop partnerships with local colleges
and universities to create a “nurse pipeline” where newly graduated
nurses are more likely to join the hospital’s workforce. Representatives
from all 11 selected hospitals discussed using this strategy to meet their
staffing needs. Competitive compensation packages may dually serve to
retain nurses, as previously described, and to recruit new nurses.
Representatives from four selected hospitals stated that their nurse
payment rates and benefits were competitive, even prior to the pandemic.
In addition, representatives at most hospitals described established
partnerships with local colleges and universities and several noted
offering sign-on and referral bonuses to nurses prior to or during the
pandemic to recruit nurses.

In response to staffing challenges during the COVID-19 pandemic, most
hospitals adjusted or enhanced existing recruitment efforts or started new
recruitment programs. For example:

•   Representatives from one hospital with an established educational
    partnership described expanding the types of nurses they recruited.
    Prior to the pandemic, representatives said that the hospital only
    recruited nurses from four-year degree programs, but that during the
    pandemic they began recruiting nurses from two-year degree
    programs and then encouraged those nurses to use the hospital’s
    educational benefits to continue their higher education.
    Representatives from another hospital said that they began offering
    free nursing school tuition to ancillary staff (personal care assistants,
    radiology technicians, etc.) during the pandemic. They noted that the
    program helps recruit ancillary staff, but in the long term, it will also
    provide new nurses who are already familiar with the hospital.
•   Representatives from three hospitals noted that each hospital
    increased both its sign-on bonuses and referral bonuses during the
    pandemic. Representatives from a fourth hospital said that the
    hospital began offering sign-on bonuses to new hires during the
    pandemic. They noted that the bonuses had conditions in place to
    ensure that new hires worked a certain number of years in exchange
    for the bonus.



Page 39                               GAO-24-106447 Hospital Use of Supplemental Nurses
Appendix IV: Strategies Used by Selected
Hospitals to Address Staffing Needs and
Changes to the Strategies during the COVID-19
Pandemic




•   Representatives from three hospitals described efforts to recruit
    supplemental nurses. Two of the three hospitals were focused on
    bringing back nurses who had left the hospital for supplemental
    employment. For instance, representatives from one of the hospitals
    described a health system-wide “welcome back home” campaign and
    noted that the effort recruited nurses who had more experience. The
    third hospital’s efforts were broader—offering direct employment into
    the hospital’s internal staffing agency to any supplemental nurses that
    had worked at the hospital (rather than only to nurses who had
    previously had direct employment at the hospital). Representatives
    said that 60 percent of these supplemental nurses offered a direct
    employment position within the hospital’s internal staffing agency
    made the conversion, with some later converting to the hospital’s
    standard permanent staff. Representatives credited their hospital’s
    work environment for the program’s success.
Nursing care delivery models. Nursing care delivery can vary by how
independent or collaborative nurses are in the provision of direct care to a
group of patients. The two predominant modes of nursing care delivery in
most acute care settings are total patient care (one RN is mainly
responsible for the complete care of a group of patients throughout a
shift) and team nursing (a designated team of both RNs and other nursing
staff with various skill levels and scopes of practice give care to a group
of patients). To meet nurse staffing challenges, a hospital may decide to
shift its approach to care delivery. Representatives from five of the 11
hospitals discussed using this strategy to meet their staffing needs. One
of the five hospitals already used this strategy prior to the COVID-19
pandemic. Representatives stated that the hospital used licensed
vocational nurses in addition to RNs in a team nursing model. 3

Four of the five hospitals began using this strategy during the pandemic
to meet their staffing needs and most continued to use the strategy at the
time of our interviews. Specifically, representatives from three hospitals
discussed shifting to a team nursing model by hiring licensed vocational
nurses to work with RNs. For instance, representatives from one hospital
explained that each nursing team consists of one RN, one licensed
vocational nurse, and one patient care technician. That team provides
care to 8 to 10 patients with the RN responsible for patient assessment

3Licensed vocational nurses have a 1-year degree, are licensed by the state, and typically
provide routine bedside care, such as taking vital signs. RNs have at least a 2-year
degree, are also licensed by the state, and are generally responsible for managing patient
nursing care and performing complex procedures, such as starting intravenous feeding or
fluids.




Page 40                               GAO-24-106447 Hospital Use of Supplemental Nurses
                      Appendix IV: Strategies Used by Selected
                      Hospitals to Address Staffing Needs and
                      Changes to the Strategies during the COVID-19
                      Pandemic




                      and the licensed vocational nurse responsible for performing tasks such
                      as wound care, medication administration, and patient education. The
                      representatives compared this to their prior model where the RN provided
                      total patient care with the assistance of one patient care technician.
                      Under that model, the RN and technician would be assigned six patients,
                      at most, with a target goal of four to five patients.

Use of Supplemental   Selected hospitals described contracting with external staffing agencies to
Nurses                bring in supplemental nurses to fill temporary daily (per diem) or longer-
                      term (for instance, 13-week assignments) staffing needs.

                      External staffing agencies. Representatives from all 11 selected
                      hospitals discussed using this strategy to meet their staffing needs.
                      Representatives from 10 of the 11 hospitals described contracting with
                      external staffing agencies to bring in supplemental nurses at least
                      occasionally prior to the COVID-19 pandemic, often to fill planned long-
                      term absences such as parental leaves. Early in the pandemic, along with
                      various combinations of other staffing strategies, six of these 10 hospitals
                      continued to use supplemental nurses at rates similar to before the
                      pandemic while two of these 10 hospitals decreased their use of
                      supplemental nurses in 2020 and the remaining two hospitals increased
                      their use of supplemental nurses in 2020. Further, the hospital that did not
                      use supplemental nurses prior to the pandemic began to do so in 2021.

                      As the pandemic continued, hospital representatives of all 11 hospitals
                      described increasing their reliance on supplemental nurses even as
                      hourly costs for these nurses also increased. For example:

                      •   Representatives at one hospital stated that as the pay rates for
                          supplemental nurses increased across the country, some of their
                          nurses left the hospital to work for external staffing agencies. They
                          explained that at the same time that nurses were leaving the hospital,
                          it also became more difficult for the hospital to recruit directly
                          employed nurses to replace them. So as the pandemic continued, the
                          hospital hired more supplemental nurses to maintain operating
                          capacity.
                      •   Representatives at another hospital described using other staffing
                          strategies during the first year of the pandemic, such as temporarily
                          reassigning their operating room nurses to assist in the intensive care
                          unit while non-essential surgeries were suspended. When the
                          hospital’s operating rooms reopened in the summer of 2020, those
                          nurses returned to their units. According to this hospital’s
                          representatives, as the pandemic continued into its second and third


                      Page 41                               GAO-24-106447 Hospital Use of Supplemental Nurses
Appendix IV: Strategies Used by Selected
Hospitals to Address Staffing Needs and
Changes to the Strategies during the COVID-19
Pandemic




    years the hospital’s staffing challenges compounded, leading to the
    hospital bringing on more supplemental nurses to meet the
    community’s needs.




Page 42                               GAO-24-106447 Hospital Use of Supplemental Nurses
Appendix V: GAO Contact and Staff
                  Appendix V: GAO Contact and Staff
                  Acknowledgments


Acknowledgments

                  Leslie V. Gordon, (202) 512-7114 or GordonLV@gao.gov
GAO Contact
                  In addition to the contact named above, Corissa Kiyan-Fukumoto
Staff             (Assistant Director), Kathryn Richter (Analyst in Charge), Nicole
Acknowledgments   Annunziata, Joy Grossman, Isabella Guyott, Giao N. Nguyen, and Dan
                  Ries made key contributions to this report. Also contributing to the report
                  were Todd Anderson, Jennie Apter, Ethiene Salgado-Rodriguez, and
                  Jennifer Rudisill.




                  Page 43                             GAO-24-106447 Hospital Use of Supplemental Nurses
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