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Executive Summary

A seismic shift is rocking the healthcare industry. Uber’s business model—the “gigification” of labor—and lobbying practices have made their way to healthcare staffing.1See Appendix C for a summary. See also Katie J. Wells and Funda Ustek Spilda, “Uber for Nursing: How an AI-Powered Gig Model Is Threatening Health Care,” Roosevelt Institute, December 17, 2024, (<)a href='https://rooseveltinstitute.org/publications/uber-for-nursing'(>)https://rooseveltinstitute.org/publications/uber-for-nursing(<)/a(>); and Katie J. Wells, Funda Ustek Spilda, Veena Dubal, and Mark Graham, (<)em(>)Fairwork US Ratings 2025: When AI Eats the Manager(<)/em(>), University of Oxford and Fairwork, 2025, (<)a href='https://fair.work/en/fw/publications/fairwork-us-ratings-2025'(>)https://fair.work/en/fw/publications/fairwork-us-ratings-2025(<)/a(>) Backed by huge sums of venture capital and private equity funds, gig nursing platforms are promoting a political agenda that limits public oversight of healthcare facilities, weakens labor protections, and exposes patients to risks.

Since 2022, lawmakers in at least seventeen states have introduced bills to recognize gig nursing platforms as a new kind of business model, one that should be regulated differently from healthcare staffing agencies. In an additional eight states, policymakers have already carved out platform work from certain state laws. In sum, efforts that would deregulate gig nursing platforms have emerged in nearly half of all US states. 

Platforms such as Clipboard Health, KARE Technologies, Nursa, and ShiftKey are using new technologically infused definitions to advance old deregulatory arguments. These platforms are trying to convince policymakers that their business model is not that of a healthcare staffing agency, and that they instead should be recognized as a “healthcare worker platform” or a “healthcare technology platform.” By renaming their businesses, gig nursing platforms are following the path of Uber, which exempted itself from regulation in dozens of states by convincing policymakers that it was not a transportation company.2Katie J. Wells, Kafui Attoh, and Declan Cullen, (<)em(>)Disrupting D.C.: The Rise of Uber and the Fall of the City(<)/em(>) (Princeton University Press, 2023). This new categorization allowed ride-hail platforms to avoid responsibility for passenger safety, minimum wages for workers, and contributions for social insurance funds.3Ibid. For the healthcare industry, the stakes of this strategy are even higher. Gig nursing platforms and their state-level campaigns threaten the stability, working conditions, and value of labor for an entire profession.

Introduction

Over the past decade, the possibility of recruiting workers on demand—without interviews, detailed background checks, orientations, or training periods—has extended into the healthcare industry, eroding the established norms, practices and guidelines for recruitment, training, and safety standards. Gig nursing platforms market themselves as efficient, data-driven solutions to persistent staffing challenges in the US healthcare system. As we have documented elsewhere, many nurses do want greater flexibility and more control over their time and working conditions.4See Wells and Ustek Spilda, “Uber for Nursing”; and Wells, Ustek Spilda, Dubal, and Graham, Fairwork US Ratings 2025: When AI Eats the Manager. So neither the problem that gig nursing platforms identify nor the solution they offer is especially new. For decades, healthcare staffing agencies filled gaps in workforces, however imperfectly. And they did so within established regulatory frameworks and labor and employment laws.

Much like Uber once cast taxi services as outdated, gig nursing platforms depict healthcare staffing agencies as obsolete and antiquated. To explain why they should be recognized as different from healthcare staffing agencies, gig nursing platforms point to their use of technology. The platforms argue that their model—with algorithmic management technologies at its core—is novel and therefore falls outside the scope of existing legal frameworks.

In this brief, we show that at least seventeen states have drafted, proposed, or passed bills that advance the idea that gig nursing platforms are not healthcare staffing agencies.5The seventeen states are California, Colorado, Georgia, Illinois, Iowa, Kansas, Louisiana, Minnesota, Missouri, Nebraska, Nevada, Ohio, Pennsylvania, Rhode Island, Tennessee, Utah, and Wisconsin. See Appendix A. Five gig nursing platforms have lobbied for such bills across multiple states, suggesting that this kind of deregulatory legislation is a strategic priority.6 The five platforms are CareRev, Clipboard Health, Kare Technologies, Nursa, and ShiftKey. See Appendix A. Although the majority of these bills remain pending or have been withdrawn, this pattern—which has unfolded since 2022—is unmistakable and shows no signs of abatement.

In light of this, the point of this report is not that healthcare staffing agencies are without flaws and that existing regulations are adequate.. Rather, we argue that the rise of gig nursing platforms prefigure a broader adoption of AI in the healthcare industry without much oversight, from patient intake and bed planning to treatment prompting and insurance coding.7See for example Chris Mills Rodrigo, “The Nurses Union Breaking Ranks to Fight AI in Hospitals,” Tech Policy Press, April 1, 2026, (<)a href='https://www.techpolicy.press/the-nurses-union-breaking-ranks-to-fight-ai-in-hospitals'(>)https://www.techpolicy.press/the-nurses-union-breaking-ranks-to-fight-ai-in-hospitals(<)/a(>). Some uses of AI simply don’t get the kind of scrutiny that clinical AI systems receive from the FDA: They fall in a regulatory gap. Investor interest in gig nursing platforms may be partly driven by this lack of scrutiny, seemingly opening up spaces for so-called innovation and disruption. However, care systems involve moral choices at every turn. They require careful and deliberate approaches to automation and surveillance. Overhauling our regulatory system to accommodate gig nursing platforms while overlooking their potential to harm workers and patients, carries significant risk to the healthcare system and the US economy.

In this brief, we outline the existing research on healthcare-focused algorithmic scheduling, staffing, and management technologies; provide a short history of third-party staffing agencies; and document the role of private equity and venture capital in the rise of gig nursing platforms. Then, we present the results of a first-of-its-kind nationwide policy analysis of legislative efforts to carve gig nursing platforms out of state laws. Alongside these findings, we highlight New York’s preemptive refusal to define these platforms as different from healthcare staffing agencies and offer a case study of Wisconsin’s debates. Finally, we warn that the quality of work and care in the healthcare industry is at risk when we let gig nursing platforms set the rules.

Gig Nursing Platforms

Background

Healthcare is one of the only growing professions left in the US.8Lydia DePillis, “Health Care Has Become the Lifeblood of the Labor Market,” New York Times, March 6, 2026, (<)a href='https://www.nytimes.com/2026/03/06/business/economy/health-care-hiring-labor-market.html'(>)https://www.nytimes.com/2026/03/06/business/economy/health-care-hiring-labor-market.html(<)/a(>). Today, nearly 15 percent of US employment is in the health- and social-assistance sector. 9Ibid. But healthcare is undergoing a seismic change as Uber’s business model—the “gigification” of labor—and its lobbying practices have made their way to the industry.10See Appendix C for a summary. See also Wells and Ustek Spilda, “Uber for Nursing”; and Wells, Ustek Spilda, Dubal, and Graham, Fairwork US Ratings 2025: When AI Eats the Manager.

Gig nursing platforms use AI-powered technologies to connect understaffed medical facilities with nearby nurses and nursing assistants looking for work. The platforms are free, with user-friendly interfaces. After a worker loads a nursing app onto her smartphone and submits the requisite documents, she can use the app to indicate her interest in specific shifts at hospitals, nursing homes, long-term care facilities, dental offices, carceral facilities, and, in some cases, Immigration and Customs Enforcement (ICE) detention centers. She can browse through shifts and roles. This freedom to choose one’s job, place, and rate has appeal. Many nurses, as we have documented elsewhere, do want greater flexibility and more control over their schedules and working conditions.11See Wells and Ustek Spilda, “Uber for Nursing”; and Wells, Ustek Spilda, Dubal, and Graham, Fairwork US Ratings 2025: When AI Eats the Manager.

In reality, the flexibility of shifts and the autonomy workers think these platforms offer may be a mirage. Many gig nursing platforms use automated decision-making systems that set pay for shifts, select a worker for a shift, notify both the facility and the worker of a match, allow a worker to clock in and clock out, send a paycheck, and, finally, create performance metrics. Such data feeds back into algorithms that determine a worker’s future access to jobs and pay rates. If the platform advertises specific rates for a shift, workers do not have the power to negotiate those rates. In short, these platforms do a lot more than merely provide a job-notice board for workers to find available shifts. The platforms play a key role in managing work in healthcare facilities.

Against this backdrop, workers may accept shifts that are farther away than they would like, pay less than they want, or take place in facilities where they would rather not work, in an effort to build a profile and ranking on the platform that might (potentially) connect them to more desirable shifts in the future. They also contend with autogenerated and opaque metrics that can turn cancellations and declined shifts into a lower standing, fewer shift offers, and even deactivation from a platform. (See Appendix C for a primer on gig nursing.)

On some gig nursing platforms, algorithmic management means workers bid against one another for shifts, enter clinical environments without paid training or facility orientation, and work within fragmented chains of command that disrupt continuity of care for patients.12See Wells and Ustek Spilda, “Uber for Nursing”; and Wells, Ustek Spilda, Dubal, and Graham, Fairwork US Ratings 2025: When AI Eats the Manager. Workers may experience surprise or “junk” fees, variable pay rates among nurses working the same shift, and missed paychecks caused by app failures linked to poor internet or cellular service—a frequent problem in rural areas.13Ibid. The cost of uniforms and unpaid labor (i.e., updating profiles, reviewing available positions, bidding for shifts, and messaging with platforms to correct account errors) can leave net pay below minimum wage rates.14Ibid.

This trend creates an illusion that fair rates for healthcare workers are algorithmically determinable. It overlooks persistent and structural undervaluation of care work, as well as the working conditions that render platform work attractive. For gig nursing platforms, there is zero transparency about how jobs are allocated, scheduled, or canceled. Different shifts and shifts associated with varying rates of pay may appear on different workers’ phones, even when the workers are in the same city and indicate the same preferences on the app.

For hospitals and medical administrators, a gig nursing platform’s control over scheduling and wage-setting is the selling point. ShiftMed promises that its algorithmic management software can “transfor[m] nurse scheduling with the power of AI.”15ShiftMed, “ShiftMed Launches ShiftAdvisor, an AI-Powered Personalized Scheduling Solution for Nurses,” press release, January 9, 2024, (<)a href='https://www.shiftmed.com/press-releases/shiftmed-launches-shiftadvisor.'(>)https://www.shiftmed.com/press-releases/shiftmed-launches-shiftadvisor.(<)/a(>) CareRev describes its software, dubbed “Smart Rates,” as “AI-driven” labor pricing that recommends “hourly shift rates based on market demand and past performance.”16“CareRev Smart Rates: Dynamic Pricing for Hospital Staffing,” CareRev, accessed April 15, 2026, (<)a href='https://www.carerev.com/solutions/smart-rates-healthcare-staffing'(>)https://www.carerev.com/solutions/smart-rates-healthcare-staffing(<)/a(>). The platform claims that its proprietary system will “effectively and competitively calculat[e] shift rates.”17CareRev, Intro to CareRev 2023: Making On-Demand Work Possible, 2023, (<)a href='https://cdn.prod.website-files.com/5babc11099f97ef511cf24a6/67fd4afdcbca1550a63b52d5_Intro_to_CareRev.pdf'(>)https://cdn.prod.website-files.com/5babc11099f97ef511cf24a6/67fd4afdcbca1550a63b52d5_Intro_to_CareRev.pdf(<)/a(>). Beth Melgren, the director of clinical operations at the Mercy Health System, which has fifty-one hospitals in the Midwest, explained why she uses a gig nursing platform: “We use AI and technology in the background to establish rates and dynamic pricing so that we offer the highest dollars where and when there is the highest need.”18“Mercy Creates Its Own Gig Workforce,” The Source, 72, Q3 2024, (<)a href='https://healthtrustpg.com/wp-content/uploads/2024/08/The-Source-Q3-2024.pdf'(>)https://healthtrustpg.com/wp-content/uploads/2024/08/The-Source-Q3-2024.pdf(<)/a(>). Another administrator who uses a gig nursing platform described how dynamic pricing helps reduce costs: “The tool allows us to be fiscally responsible in our shifts because, without the solution, we would probably blanket a pay increase for whoever picked up a shift.”19Niel Oscarson and Maddie Calder, Trusted Health Works 2024: Reducing Clinician Burnout with a User-Friendly Scheduling Platform, KLAS Research, October 23, 2024, (<)a href='https://klasresearch.com/report/trusted-health-works-2024-reducing-clinician-burnout-with-a-user-friendly-scheduling-platform/3606'(>)https://klasresearch.com/report/trusted-health-works-2024-reducing-clinician-burnout-with-a-user-friendly-scheduling-platform/3606(<)/a(>).

The rise of gig nursing platforms reflects a broader turn toward AI in the healthcare industry writ large, as AI systems increasingly mediate the relationship between workers and employers, giving those who control employment decisions more centralized power. These changes invoke troubling questions about algorithmic collusion and wage suppression. Opaque and personalized pay structures can create “surveillance wages,”20AI Now Institute et al., Prohibiting Surveillance Prices and Wages, American Economic Liberties Project, February 2025, https://www.economicliberties.us/wp-content/uploads/2025/02/Real-Surveillance-Prices-and-Wages-Report.pdf. or what Veena Dubal terms “algorithmic wage discrimination,” a kind of discrimination in which workers’ personal data is used to create ever-changing wages.21Veena Dubal, “On Algorithmic Wage Discrimination,” Columbia Law Review 123, no. 7 (November 2023): 1929–2004, https://www.columbialawreview.org/wp-content/uploads/2023/11/Dubal-On_Algorithmic_Wage_discrimination.pdf. Companies can, explains Nina DiSalvo, use “signals associated with financial vulnerability, including data on whether a prospective employee has taken out a payday loan” to infer how low of a rate a worker might accept.22Genna Contino, “Employers Are Using Your Personal Data to Figure Out the Lowest Salary You’ll Accept,” MarketWatch, April 1, 2026, https://www.marketwatch.com/story/employers-are-using-your-personal-data-to-figure-out-the-lowest-salary-youll-accept-c2b968fb. The ability of companies to purchase, collect, and screen individualized worker data can reduce wages and fairness in the workplace.23See Veena Dubal and Wilneida Negron, How Artificial Intelligence Uncouples Hard Work from Fair Wages Through “Surveillance Pay” Practices—and How to Fix It, Washington Center for Equitable Growth, August 21, 2025, https://equitablegrowth.org/how-artificial-intelligence-uncouples-hard-work-from-fair-wages-through-surveillance-pay-practices-and-how-to-fix-it (https://equitablegrowth.org/how-artificial-intelligence-uncouples-hard-work-from-fair-wages-through-surveillance-pay-practices-and-how-to-fix-it/); and PowerSwitch Action and Gig Workers Rising, Uber’s Inequality Machine: Data on How AI-Driven Pay Is Harming Workers and What We Can Do to Push Back, PowerSwitch Action, June 2025, https://www.powerswitchaction.org/resources/ubers-inequality-machine.

Prevalence

Gig nursing platforms have found tremendous financial support. Three platforms—Clipboard Health, IntelyCare, and ShiftKey—have achieved unicorn status with valuations of $1 billion each.24See Appendix B. ShiftKey raised more than $300 million from private equity alone, a feat that underscores the anticipated growth of this business model.25Emily Olsen, “Healthcare Staffing Startup ShiftKey Raises $300M,” Mobi Health News, January 13, 2023, https://www.mobihealthnews.com/news/healthcare-staffing-startup-shiftkey-raises-300m. Our research indicates that this is not a situation in which a few platforms are carving out a space for themselves alongside staffing agencies (and thus emerging as a third player in the field). Instead, gig nursing platforms are in the process of reshaping rules for an entire healthcare industry.

Gig nursing platforms now exist in every US state. CareRev claims it is active in 650 facilities,26“Why Hospitals Choose CareRev,” CareRev, accessed April 15, 2026, https://www.carerev.com/why-partner-with-carerev. while ShiftMed reports contracts with two thousand facilities.27Anna Falvey, “Great Leaders in Healthcare 2025,” Becker’s Hospital Review, March 13, 2025, https://www.beckershospitalreview.com/lists/great-leaders-in-healthcare-2025 (https://www.beckershospitalreview.com/lists/great-leaders-in-healthcare-2025/). SSM Health, which has more than two dozen hospitals, partnered with ShiftMed to fill twenty-one thousand shifts in a single quarter.28Gretchen Berlin et al., “How to Bridge the Experience Gap by Supporting Nurses of All Tenures,” McKinsey & Company, March 28, 2024), https://www.mckinsey.com/industries/healthcare/our-insights/how-to-bridge-the-experience-gap-by-supporting-nurses-of-all-tenures. Clipboard Health (also known as Twomagnets LLC) has “managerial control”29See for example Centers for Medicare and Medicaid Services, The Cove at La Jolla: Inspection Reports (February 2026), archived at ProPublica, https://projects.propublica.org/nursing-homes/homes/h-555545. of dozens of nursing and rehab properties, including those owned by the for-profit chain Ensign Group. ShiftKey, which has announced its intention to expand into other licensed professions such as therapy and dentistry,30David Seeley, “$2B Healthcare Staffing Platform ShiftKey Announces Leadership Moves, New Brand Identity,” Dallas Innovates, July 12, 2023, https://dallasinnovates.com/2b-healthcare-staffing-platform-shiftkey-announces-leadership-moves-new-brand-identity (https://dallasinnovates.com/2b-healthcare-staffing-platform-shiftkey-announces-leadership-moves-new-brand-identity/). says it has partnerships with ten thousand organizations.31“Over 10,000 Organizations Trust ShiftKey,” ShiftKey, 2026, https://www.shiftkey.com/facilities/testimonials. Praising this trend, Fast Company named ShiftKey one of the most innovative companies of 2024;32AJ Hess, “The Most Innovative Human Resources Companies of 2024,” Fast Company, March 19, 2024, https://www.fastcompany.com/91040139/human-resources-most-innovative-companies-2024. Business Insider recognized Clipboard Health as one of the most promising start-ups of 2023.33Julie Bort, Samantha Stokes, and Rebecca Torrence, “These Are the 16 Most Promising Healthcare Startups of 2023, According to Top VCs,” Business Insider, July 19, 2023, https://www.businessinsider.com/vcs-most-promising-startups-healthtech-2023-6.

The annual costs that a healthcare facility, whether public or private, spends on gig nursing platforms can vary from tens of thousands to millions of dollars.34A nursing home in Colorado reported $2.9 million for services from Kare Technologies in 2022. See Sunny Vista Living Center, Return of Organization Exempt from Income Tax: Form 990, 2022, https://www.intellispect.co/organizations/840438016-sunny-vista-living-center. A Chicago hospital similarly spent more than $2.7 million in annual expenses for CareRev’s services in 2023. See Saint Anthony Hospital, Return of Organization Exempt from Income Tax: Form 990, 2022, (<)a href='https://projects.propublica.org/nonprofits/organizations/510217097/202433269349301133/IRS990'(>)https://projects.propublica.org/nonprofits/organizations/510217097/202433269349301133/IRS990(<)/a(>). When nursing or medical facilities are publicly run, questions arise about the extent to which the government is propping up this business model and its AI-powered management systems. Public facilities in Illinois,35McLean County Board Health Committee, Minutes of the Health Committee, September 14, 2021, https://www.mcleancountyil.gov/ArchiveCenter/ViewFile/Item/8493. Kansas,36Atchison County Commission, Atchison County Commission Meeting: New Business, July 2, 2024, (<)a href='https://www.atchisoncountyks.org/AgendaCenter/ViewFile/Agenda/_07022024-1223?packet=true'(>)https://www.atchisoncountyks.org/AgendaCenter/ViewFile/Agenda/_07022024-1223?packet=true(<)/a(>). Pennsylvania,37Cumberland County Commissioners Workshop, Agenda, June 10, 2021, https://www.cumberlandcountypa.gov/DocumentCenter/View/38549/06-10-2021-Workshop-Agenda. Arkansas,38Arkansas Department of Shared Administrative Services, ALC Review, February 6, 2026, https://arkleg.state.ar.us/Home/FTPDocument?path=%2FAssembly%2FMeeting+Attachments%2F010%2F27786%2FE.+Contracts.pdf. New Hampshire,39Rockingham County Commissioners, Meeting Minutes, January 4, 2024, https://rockinghamcountynh.org/wp-content/uploads/2024/12/2024-Minutes-Updated-12.20.24.pdf. and Texas40Yoakum County, A/P History Check Report, November 17, 2025 (archived December 12, 2025), (<)a href='https://web.archive.org/web/20251212213957/https://www.co.yoakum.tx.us/upload/page/4200/2025/AP%20Check%20Report%20-%204499.pdf'(>)https://web.archive.org/web/20251212213957/https://www.co.yoakum.tx.us/upload/page/4200/2025/AP%20Check%20Report%20-%204499.pdf(<)/a(>). have contracts with gig nursing platforms. Nashville General Hospital recently signed a contract with ShiftKey.41ShiftKey, “ShiftKey Is Selected by Nashville General Hospital to Help Champion Local Independent Nurses and Support the Community,” press release, KFLY & Globe Newswire, June 5, 2025, https://www.klfy.com/business/press-releases/globenewswire/9463405/shiftkey-is-selected-by-nashville-general-hospital-to-help-champion-local-independent-nurses-and-support-the-community (https://www.klfy.com/business/press-releases/globenewswire/9463405/shiftkey-is-selected-by-nashville-general-hospital-to-help-champion-local-independent-nurses-and-support-the-community/). So did the Department of Veterans Affairs in Kentucky—at an annual cost to the public of $1 million.42Kentucky Legislative Research Commission, Government Contract Review Committee, Personal Service Contract List: 2500002187, April 2025, https://apps.legislature.ky.gov/moreinfo/contracts/2004%20Keifer%20Data%20Base/PSC/250400.pdf. This was the sum the government paid to the platform; we do not know which types of workers were contracted, how much income workers earned from the shifts, or how many shifts were scheduled. Gig nursing platforms tend to shield many of their operations from view.

A Precursor and a Competitor: Staffing Agencies

Third-party staffing agencies are not new to healthcare. For the first half of the twentieth century, most hospital-based nurses worked through nurse-run agencies called private-duty registries. In the 1950s, this arrangement changed as hospitals began to hire nurses directly, build internal nurse pools, and gain an upper hand in staff management. Within two decades, most nurses in hospitals were employees, many of whom had less control over their schedules and wages than in the days of private-duty registries.43See Jean C. Whelan, Nursing the Nation: Building the Nurse Labor Force (Rutgers University Press, 2021); see also Patricia D’Antonio et al., “Histories of Nursing: The Power and the Possibilities,” Nursing Outlook 58, no. 4 (July/August 2010): 207–13, (<)a href='https://www.nursingoutlook.org/article/S0029-6554(10)00247-2/abstract'(>)https://www.nursingoutlook.org/article/S0029-6554(10)00247-2/abstract(<)/a(>).

External staffing agencies, also called healthcare staffing agencies or travel nursing agencies, still exist and are a main competitor for gig nursing platforms. Hospitals and medical facilities use staffing agencies to plug gaps in coverage, which can occur for a variety of reasons, such as the temporary unavailability of existing staff or ad hoc demands at a facility.

These agencies are typically subject to state-level governmental oversight and varying regulatory requirements. However, the ground beneath these regulations has shifted in recent years. A surge in attention to the healthcare staffing industry arose in the wake of the Covid-19 pandemic. During the pandemic, staffing agencies were accused of price gouging and risking patient safety with unvetted workers. As a result, a number of states, including Colorado, Minnesota, and New York, adopted new laws to strengthen governmental oversight of staffing agencies.44See “Required Reporting by Supplemental Healthcare Staffing Agencies,” Colorado Department of Labor and Employment, https://cdle.colorado.gov/dlss/labor-laws-by-topic/required-reporting-by-supplemental-healthcare-staffing-agencies; “Supplemental Nursing Services Agency,” Minnesota Department of Health, https://www.health.state.mn.us/facilities/regulation/snsa/index.html; and “Registration of Temporary Health Services Agencies and Health Care Technology Platforms,” New York State Department of Health, https://www.health.ny.gov/facilities/staffing_agency/. Most of these laws require that agencies register annually, disclose shareholders and executive officers, certify worker credentials, report to state authorities on the number of workers employed, document service rates charged to facilities, and list average wages paid to workers by job category. These laws also prohibit agencies from subjecting workers to noncompete agreements and finder’s fees.

The shortcomings of healthcare staffing agencies often serve as a reference point for gig nursing platforms, which present themselves as a welcome alternative. On one hand, gig nursing platforms describe themselves as a competitor to healthcare staffing agencies; on the other, they contend that they should not be subject to the same kinds of rules that govern healthcare staffing agencies. This is complicated by some platforms using an employment model (instead of an independent contractor model) to recruit and appoint nurses to facilities.

Thus, it is no wonder confusion abounds about the similarities and differences between these businesses. Agencies and platforms collect revenue from identical sources. They both take cuts of the wages paid to workers and the fees charged to facilities. And the defining feature of each of their businesses is that they offer temporary staff to hospitals, nursing homes, and other medical facilities. ShiftKey’s home page presents the platform as “connect[ing] licensed professionals and facilities all around the country.”45“Thousands of Choices on One Platform,” ShiftKey, accessed April 15, 2026, (<)a href='https://www.shiftkey.com (https://www.shiftkey.com/'(>)https://www.shiftkey.com(<)/a(>). One of the country’s largest travel nursing agencies, Aya Healthcare, likewise describes its business as “directly connecting you with leading healthcare facilities.”46“Travel Nursing, Allied & Per Diem Jobs, Aya Healthcare, accessed April 15, 2026, (<)a href='https://www.ayahealthcare.com (https://www.ayahealthcare.com/'(>)https://www.ayahealthcare.com(<)/a(>).

That said, there are three key differences between gig nursing platforms and healthcare staffing agencies. First, shifts are often much shorter on gig nursing platforms, which usually facilitate only single-day shifts. Agencies, by contrast, arrange multiweek contracts for “travel nurses” at a single facility. Second, gig nurses evaluate posted shifts on their own; there exists scant human intermediation for these workers. Healthcare staffing agencies, however, mediate between a facility and a worker, arranging interviews and helping to evaluate whether the match is a good one. Third, gig nursing platforms can exert more control over healthcare workers than agencies because the AI-powered software installed on a worker’s phone can track and evaluate certain metrics about their workplace performance. Healthcare staffing agencies typically do not collect or track such finite data.

Corporate Finance Enters the Story

Private firms have grown increasingly interested in investing in gig nursing platforms. The ten most prominent gig nursing platforms have raised nearly $1.4 billion in funds. (See Appendix B for a summary of the funding.) The investments stem from a mix of venture capital (VC) firms, private-equity and growth-equity investors (which differ from VC firms that focus only on start-ups), accelerators, and start-up programs. ShiftKey raised over $300 million in 2023, entirely through private equity.47Keerthi Vedantam, “Healthcare Employment ‘Matchmaker’ ShiftKey Raises $300M, Valued at $2B,” Crunchbase News, January 11, 2023, https://news.crunchbase.com/health-wellness-biotech/employment-shiftkey-fundraise (https://news.crunchbase.com/health-wellness-biotech/employment-shiftkey-fundraise/). The platform is now valued at $2 billion.48Ibid. CareRev reached a $600 million valuation in 2022.49Marina Temkin, “Incredible Health: Investors Target Recession-Resilient Healthcare Recruiting Startups,” PitchBook, August 16, 2022, https://pitchbook.com/news/articles/incredible-health-hr-tech-nursing. Clipboard Health’s latest valuation was $1.3 billion, after having raised $90 million in capital from Y Combinator, a DoorDash co-founder,50“Sequoia Capital Leads Clipboard Health $30M Series C Round at $1.3bn Valuation,” Private Equity Wire, April 19, 2022, (<)a href='https://www.privateequitywire.co.uk/sequoia-capital-leads-clipboard-health-30m-series-c-round-13bn-valuation'(>)https://www.privateequitywire.co.uk/sequoia-capital-leads-clipboard-health-30m-series-c-round-13bn-valuation(<)/a(>). and other venture capital firms.51Kyle Wiggers, “Clipboard Health, Which Matches Health Workers with Facilities, Raises $80M,” TechCrunch, April 18, 2022, (<)a href='https://techcrunch.com/2022/04/18/clipboard-health-which-matches-health-workers-with-facilities-raises-80m'(>)https://techcrunch.com/2022/04/18/clipboard-health-which-matches-health-workers-with-facilities-raises-80m(<)/a(>).

The enormous investments to date in gig nursing platforms, as well as the involvement of a wide range of private-equity firms and VCs, raise serious concerns. Private-equity investments have been associated with declining quality of care in the healthcare industry.52Rebecca Adams, “Why States Are Cracking Down on Private Equity in Health Care,” Intelligence Report, Washington Post, January 21, 2026, (<)a href='https://wpintelligence.washingtonpost.com/topics/2026/01/21/whats-coming-next-oversight-private-equity-health-care'(>)https://wpintelligence.washingtonpost.com/topics/2026/01/21/whats-coming-next-oversight-private-equity-health-care(<)/a(>). In nursing homes, private-equity backing has led to adverse outcomes, including higher mortality rates, compliance violations, lower quality of life for patients, and understaffing.53Atul Gupta et al., “Does Private Equity Investment in Healthcare Benefit Patients? Evidence from Nursing Homes,” Becker Friedman Institute for Economics, Working Paper no. 2021–20, University of Chicago, February 17, 2021, https://bfi.uchicago.edu/insight/research-summary/does-private-equity-investment-in-healthcare-benefit-patients-evidence-from-nursing-homes. The pattern is similar in hospitals. Not long after a private-equity firm purchased a hospital in Connecticut, the facility began to receive citations for patient abuse, rusty operating equipment, and unsanitized patient tables.54Sujata Srinivasan, “‘Personal Piggy Banks’: US Senate Investigation Rails Against Private Equity Draining CT Hospitals,” Connecticut Public Radio, January 9, 2025, https://www.ctpublic.org/news/2025-01-09/private-equity-senate-report-connecticut-prospect-medical. The emergency room, too, was understaffed 80 percent of the time.55Sujata Srinivasan, “Staffing Problems Persist at Prospect-Owned Waterbury Hospital, Union Leader Says,” Connecticut Public Radio, September 26, 2024, https://www.ctpublic.org/news/2024-09-26/prospect-waterbury-hospital-staffing.

A Deregulation Campaign

State Policies

Since 2022, gig nursing platforms have sought to legalize their business model through state-level legislation, administrative rulemaking, and a ballot measure. Five of the ten most prominent gig nursing platforms have engaged in state-level lobbying efforts to exempt their platforms from regulatory oversight. Clipboard Health lobbied in Georgia to exempt gig nursing platforms from state unemployment insurance and workers’ compensation laws.56Georgia H.B. 991, Reg. Sess. (2025–26), (<)a href='https://www.legis.ga.gov/legislation/72258'(>)https://www.legis.ga.gov/legislation/72258(<)/a(>). ShiftKey and Clipboard Health have supported an Ohio bill to classify gig nurses as independent contractors, exempting gig platforms from minimum wage and other worker protection laws.57Ohio H.B. 277, 136th General Assembly, Reg. Sess. (2025–26), (<)a href='https://www.legislature.ohio.gov/legislation/136/hb277'(>)https://www.legislature.ohio.gov/legislation/136/hb277(<)/a(>). ShiftKey supported a bill in Iowa that would exempt gig nursing platforms from various reporting requirements and make it easier for gig nursing platforms to treat their workers as independent contractors.58Iowa H.F. 2698, 90th General Assembly (2024), (<)a href='https://www.legis.iowa.gov/legislation/BillBook?ga=90&ba=HF%202698&v=e'(>)https://www.legis.iowa.gov/legislation/BillBook?ga=90&ba=HF%202698&v=e(<)/a(>). A Utah state senator approvingly described a similar bill as “lightest-touch regulation.”59Utah State Legislature, House Health and Human Services Committee: March 04, 2025, March 4, 2025, video, https://le.utah.gov/av/committeeArchive.jsp?timelineID=277350. The general counsel for Nursa publicly agreed that the Utah bill was admirable because of how little it did to regulate gig nursing platforms.60Oddly, this general counsel introduced himself in the record not as an executive at Nursa but as a representative of something called the “Healthcare Marketplace Coalition,” an entity that does not yet appear to exist. See Utah State Legislature, House Health and Human Services Committee. Collectively, these policies constitute a new deregulatory agenda—one that threatens to undermine the quality of millions of healthcare jobs. (See Appendix A for a detailed summary of state policies.)

These public-policy efforts can be sorted into two types: (1) policies that exempt gig nursing platforms from worker protection laws; and (2) policies that exempt gig nursing platforms from certain healthcare staffing agency regulations.

The first type of policy deployed by gig nursing platforms exempts platforms from existing state worker-protection laws. Gig nursing platforms have enlisted lobbyists to argue that technologically mediated businesses are so unique that they constitute new business categories and, as a result, merit carveouts from existing laws. Such policies have advanced in six states: Georgia, Ohio, Pennsylvania, California, Missouri, and Wisconsin. (See Appendix A for more information.)

This strategy uses a playbook developed by ride-hailing giant Uber that succeeded in dozens of states.61See Jennifer Sherer and Margaret Poydock, Flexible Work Without Exploitation, Economic Policy Institute, February 23, 2023, https://www.epi.org/publication/state-misclassification-of-workers (https://www.epi.org/publication/state-misclassification-of-workers/); Dan Ocampo, Laura Padin, and Mariah Montgomery, The Bully’s Playbook: How App Corporations Hold Back Worker Organizing and Harm Democracy, National Employment Law Project and PowerSwitch Action, May 22, 2024, https://www.nelp.org/insights-research/the-bullys-playbook-how-app-corporations-hold-back-worker-organizing-and-harm-democracy; Katie J. Wells, Declan Cullen, and Kafui Attoh, “Inside Uber’s Political Machine,” New York Review, May 9, 2024, https://www.nybooks.com/online/2024/05/09/inside-uber-political-machine (https://www.nybooks.com/online/2024/05/09/inside-uber-political-machine/). Where Uber created the Transportation Network Company (TNC) category and UberEats invented the Delivery Network Company (DNC) model, gig nursing platforms have introduced a “health care worker platform” business category.62One difference between the campaigns advanced by Uber and those of gig nursing platforms is that the latter have not employed direct text messages to platform workers or facility administrators about political campaigns. What is worrying about this new category is how it is being used to erode working conditions in the care economy. Gig nursing bills define a “health care worker platform”63Other iterations of this new moniker include “healthcare worker platform,” “health services platform,” “digital health care service platform,” “health care technology platform,” and “health care contractor platform.” as an entity that engages workers as independent contractors and not employees (of platforms or the facility owners that contract with them), state worker-protection laws if certain conditions are met. The list of conditions—the test—is designed to allow any gig nursing platform that wishes to engage its workers as independent contractors to do so. Tests that exempt platforms from existing worker protections often play up factors that indicate worker independence and control, and downplay factors that show platform or facility control. In doing so, the tests likely fail to fully gauge the power dynamic between workers and the platforms and facilities that hire and manage them.

For example, the criteria in these assessments may overlook the role of facility owners in jointly managing nursing platform workers.64Factors purported to measure workers’ scheduling flexibility are carefully worded to allow platforms to use incentive and discipline structures that compel workers to make specific scheduling choices. The tests establish requirements such as “platform does not require the healthcare worker to use specific equipment” and “platform does not prescribe or control the means and methods for the services performed,” when it would be customary for such control to be exerted by facility owners and their directly employed staff.65Gig nursing platform workers typically plug into existing hierarchical staffing systems involving doctors, nurses, certified nurse aides, and nursing assistants who are directly employed by medical facilities. Large hospital and nursing-home systems, educational institutions, carceral facilities, and other entities that contract with nursing platforms are somewhat hidden beneficiaries of these Uber-style carveout efforts. As potential worksite employers of the platform workers, they could share legal responsibility with platforms for working conditions that they have a strong hand in shaping. But the Uber-style carveout policies explicitly rid facility owners, alongside platforms, of employer liability.

In lobbying for these public policies, gig nursing platforms and their supporters may flat out misrepresent the level of control that platforms have over workers.66Another instance of misrepresentation happened at a hearing in Rhode Island when a Clipboard Health lobbyist testified that the platform “doesn’t make any payments. […] It’s direct from the employer to the employee. Clipboard does not negotiate rates.” Rhode Island Capitol TV, House Committee on Health and Human Services: 1-29-2026, January 29, 2026, video, (<)a href='https://capitoltvri.cablecast.tv/show/11704?currentDay=2026-02-11'(>)https://capitoltvri.cablecast.tv/show/11704?currentDay=2026-02-11(<)/a(>). A state senator in Wisconsin, who cosponsored a bill to exempt gig nursing platforms from state employment laws, testified earlier this year that gig nursing platforms are simply bulletin boards:

Worker platforms serve as an online bulletin board, showing workers when and where job shifts are available. Workers then sign up for shifts, and they are paid by the health care provider. This bill makes clear that the worker is not an employee of the bulletin board.67Testimony on Senate Bill 768, State of Wisconsin Senate Committee on Health (January 14, 2026) (statement of Van H. Wanggaard), (<)a href='https://docs.legis.wisconsin.gov/misc/lc/hearing_testimony_and_materials/2025/sb768/sb0768_2026_01_14.pdf'(>)https://docs.legis.wisconsin.gov/misc/lc/hearing_testimony_and_materials/2025/sb768/sb0768_2026_01_14.pdf(<)/a(>).

The bulletin-board analogy, while memorable in its simplicity, is false. Workers for ShiftKey, Clipboard Health, and dozens of other gig nursing platforms are not paid by the healthcare provider. Nor is it possible on a platform to see all shifts in a region; facilities must contract with platforms for their shifts to be listed. Additionally, workers are not able to communicate directly with facilities through platforms. Workers cannot negotiate rates, discuss conditions, or learn more about job responsibilities—all of which would be possible if a worker found a shift listed on a bulletin board. Gig nursing platforms arrange payment and oversee a variety of other parameters. A platform generally vets applicants, scores performance, sets rates, collects fees, and includes clocking-in and clocking-out functionality on its app. And, because the platform contracts with health facilities directly, it also controls the overall availability of shifts; in other words, an open shift won’t be advertised on multiple apps at the same time.

However, for all its shortcomings, the bulletin-board analogy does illuminate a key tactic by platforms and their supporters: to downplay the level of control that platforms exert over workers and thus convince policymakers that there is a new kind of business called a “health care worker platform.” It is this kind of “definitional arbitrage”68Veena Dubal, “Data Laws at Work,” Yale Law Journal Forum 134 (January 31, 2025), (<)a href='https://yalelawjournal.org/forum/data-laws-at-work'(>)https://yalelawjournal.org/forum/data-laws-at-work(<)/a(>). that helps set debates around labor protections and regulations in the healthcare industry.

A second and more common strategy that gig nursing platforms use to promote their deregulation campaign involves exempting themselves from healthcare staffing agency regulations. Gig nursing platforms have advanced bills to carve themselves out of various requirements, such as mandated regular reports to the state on the average wages paid to workers and the average rates charged to facilities by category of worker. These policies have advanced in eight states: Colorado, Illinois, Iowa, Louisiana, Minnesota, Missouri, Nevada, and Rhode Island. (See Appendix A for more details.) The bill in Colorado, which became law, likely goes the furthest for a deregulatory agenda by exempting gig nursing platforms from all healthcare staffing agency regulations.78Colorado S.B. 22-210, Reg. Sess. (2022), https://leg.colorado.gov/bills/SB22-210.

All of the bills that exempt gig nursing platforms from healthcare staffing agency regulations include language designed to help platforms legally hire workers as independent contractors.79When gig nursing platforms label their workers as “independent contractors” rather than “employees,” platforms often violate local, state, and federal employment laws, including those that set minimum wage and overtime wage rates, prohibit workplace discrimination, and require contributions to workers’ compensation, unemployment insurance, and Social Security funds. The language consists of phrasing along the lines of “For the purposes of this chapter, a gig nursing platform engages workers as independent contractors.” Although this verbiage technically only legalizes treatment of gig nursing platform workers as independent contractors in one instance (under the law related to healthcare staffing agency regulations), it establishes a definition likely to be cited elsewhere in the future. These definitions are particularly concerning because regulators, courts, and future policy drafters could defer to this codified language to keep definitions consistent, and gig nursing platforms could then cite these laws if they face legal claims alleging independent contractor misclassification or related violations of state worker-protection laws.

In some cases, these definitions of gig nursing platforms have slipped quietly into proposals about healthcare staffing agency regulations without fanfare. Earlier this year, for instance, the Nebraska state legislature convened a hearing on a bill that would increase licensure vetting requirements for staffing agencies and define a “health care technology platform” as a company that is distinct from healthcare staffing agencies.80Nebraska Health Care Staffing Agency Registration Act, L.B. 308, 109th Leg., 1st Sess. (2025), (<)a href='https://nebraskalegislature.gov/FloorDocs/109/PDF/Intro/LB308.pdf'(>)https://nebraskalegislature.gov/FloorDocs/109/PDF/Intro/LB308.pdf(<)/a(>). Owners of long-term care facilities testified that they needed the proposed legislation because staffing agencies are not doing a good job of screening employees. Not once, however, did they or any other speaker at the hearing mention the new definition, which could change how healthcare staffing is regulated far into the future.81Nebraska Legislature, Business and Labor Committee, Transcript of the Public Hearing on L.B. 308, 109th Leg., 1st sess., January 27, 2025, (<)a href='https://nebraskalegislature.gov/FloorDocs/109/PDF/Transcripts/Business/2025-01-27.pdf'(>)https://nebraskalegislature.gov/FloorDocs/109/PDF/Transcripts/Business/2025-01-27.pdf(<)/a(>).

Beyond Legislation

In addition to legislation, gig nursing platforms have used two other policy vehicles to advance their deregulation campaign. First, a ballot measure in California was proposed to deregulate gig nursing platforms in 2022. The measure, which was later withdrawn,82“Nursing Is Not a Side Job. Protect Patients. Reject ‘Gig’ Nursing,” National Nurses United, accessed April 15, 2026, https://www.nationalnursesunited.org/gig-nursing. would have carved nursing platform workers out of all California employment laws.83Jaclyn Galica and Courtney McDermed, “Proposed Initiative Statute: Equitable Access to Health Care Services Act,” California Initiative 22-0003, submitted to the Attorney General of California, January 24, 2022, https://oag.ca.gov/system/files/initiatives/pdfs/22-0003%20%28Health%20Care%20Workers%20%29.pdf. Ballot measures about gig nursing platforms have not yet materialized in other states, but their appearance would not be unexpected. Historically, a ballot measure strategy enables passage of antiworker policies, like those of gig nursing platforms, in bluer states where deep-pocketed corporations can inundate voters with disinformation about the issue. Second, gig nursing platforms have taken an under-the-radar approach to seek changes in administrative rules that lay out how a law will be implemented. These rules are not subject to legislative approval and can change at any time. Administrative rules have recently added definitions of gig nursing workers (and stipulated that they are independent contractors) in Missouri, where ShiftKey has lobbied, and in Louisiana.84See Missouri Department of Health and Senior Services, “Statutes & Regulations: Supplemental Health Care Service Agencies,” 2022–23, https://health.mo.gov/safety/shcsa/laws-and-regulation.html; and Louisiana Department of Health, “NSA Rulemaking Activity: NSA Licensing Standards,” June 11, 2025, https://ldh.la.gov/health-standards-section/nsa-rm. In Utah, platform advocates have proposed an administrative rule to undermine enforcement of already-weak nursing platform regulations.85See Utah Department of Commerce, Division of Professional Licensing, “Nursing: Laws and Rules,” https://commerce.utah.gov/dopl/nursing/laws-and-rules (https://commerce.utah.gov/dopl/nursing/laws-and-rules/); Proposed Rule R156-46b: Division Utah Administrative Procedures Act Rule, Utah State Bulletin, OAR No. 57787 (proposed February 2026), https://commerce.utah.gov/wp-content/uploads/2026/02/proposed-rule-r156-46b-division-utah-administrative-procedures-act-rule-oar.57787.pdf; and Utah Code § 63G-4-203, https://le.utah.gov/xcode/Title63G/Chapter4/C63G-4-S203_1800010118000101.pdf.

Federal Efforts

In recent years, Clipboard Health and ShiftKey have spent more than $1.1 million on federal lobbying.86ShiftKey reported spending $240,000 on federal lobbying in 2025, $680,000 in 2024, and $60,000 in 2023. Clipboard Health reported spending $160,000 for federal lobbying about the legal classification of its workforce in 2025. See “Registrations & Quarterly Activity,” Lobbying Disclosure Act Reports, United States Senate, https://lda.senate.gov/filings/public/filing/search (https://lda.senate.gov/filings/public/filing/search/). Clipboard Health has lobbied the Department of Labor for “[w]orker classification clarification,”87Lobbying Disclosure Act Report for ShiftKey, LLC, filed by Converge Public Strategies, 2025, https://lda.senate.gov/filings/public/filing/df32ba6f-33d4-4f3e-810d-6629da954b0a/print (https://lda.senate.gov/filings/public/filing/df32ba6f-33d4-4f3e-810d-6629da954b0a/print/). while ShiftKey has engaged members of the US Senate, House of Representatives, and Federal Trade Commission to “[p]rovide strategic counsel and advocate on issues related to healthcare workforce and technology and independent contractor classification.”88Lobbying Disclosure Act Report for ShiftKey, LLC, filed by BGR Government Affairs, 2024, https://lda.senate.gov/filings/public/filing/9cbda3f9-58b4-4372-9120-9367fec4b582/print (https://lda.senate.gov/filings/public/filing/9cbda3f9-58b4-4372-9120-9367fec4b582/print/). ShiftKey has also been a vocal advocate for federal bills that are permissive of independent-contractor labor models and strip workers of bedrock wage and organizing rights.

Other gig nursing platforms—CareRev, Nursa, Kare, MedCurate, Medely, and HealthBar—have lobbied to grow “independent work” in general through the multi-industry Coalition for Workforce Innovation (CWI), which includes Amazon and Uber.89“Our Members,” Coalition for Workforce Innovation, accessed April 15, 2025, https://workforceinnovation.net/members. Through the CWI, gig nursing platforms have voiced support for policies that would narrow their workers’ access to federal-wage, unionizing, and collective-bargaining rights.90Coalition for Workforce Innovation, “CWI Supports Senate Efforts to Support Independent Workers,” press release, July 9, 2025, https://workforceinnovation.net/cwi-news/f/cwi-supports-senate-efforts-to-support-independent-workers. In 2022, for instance, CareRev and the CWI supported a Trump administration interpretive rule that narrowed access to federal-minimum-wage, overtime, and child-labor protections in the Fair Labor Standards Act.91Employee or Independent Contractor Classification Under the Fair Labor Standards Act, 87 Fed. Reg. 62218 (proposed October 13, 2022), https://www.federalregister.gov/documents/2022/10/13/2022-21454/employee-or-independent-contractor-classification-under-the-fair-labor-standards-act.

ShiftKey has been a vocal advocate for federal legislation that would give it and other businesses a “safe harbor” against employer classification under federal laws for providing “portable benefits” to workers.92See US Congress, Senate, Unlocking Benefits for Independent Workers Act, S. 2210, 119th Cong., 1st sess., 2025, https://www.congress.gov/bill/119th-congress/senate-bill/2210/text; a (https://www.linkedin.com/posts/myshiftkey_how-a-new-bill-to-make-benefits-portable-activity-7353221866368471040-xKsf)nd Kayla Webster, “How a New Bill to Make Benefits Portable for Gig Workers Could Benefit Thousands in Pennsylvania,” Inc., July 18, 2025, (https://www.linkedin.com/posts/myshiftkey_how-a-new-bill-to-make-benefits-portable-activity-7353221866368471040-xKsf) https://www.inc.com/kaylawebster/how-a-new-bill-to-make-benefits-portable-could-help-entrepreneurs/91215665. These portable-benefits schemes more often than not give workers benefits worth less than what they would receive by law as employees and undermine existing social-insurance programs.93Billy Bonnist and Max Feist, “Workers Need Real Security and Flexibility, Not Pro-Employer Portable Benefits Proposals,” Economic Policy Institute, July 17, 2025, https://www.epi.org/blog/workers-need-real-security-and-flexibility-not-pro-employer-portable-benefits-proposals (https://www.epi.org/blog/workers-need-real-security-and-flexibility-not-pro-employer-portable-benefits-proposals/); “Workers Need Real Portable Benefits and Access to Foundational Employment Rights,” National Employment Law Project, https://www.nelp.org/workers-need-real-portable-benefits-and-access-to-foundational-employment-rights. Through the CWI, CareRev, Nursa, Kare, MedCurate, Medely, and HealthBar have voiced support for the same legislation.94Coalition for Workforce Innovation, “CWI Supports Senate Efforts to Support Independent Workers.”

In 2025, a bill allowing the US president to contract with and deploy gig nursing platforms—specifically those with “independent contractor health care workers”—during declared emergencies was introduced in the US Senate and House of Representatives.95US Congress, Senate, Strategic Teams for Organized Response Mobilization Act, S. 1701, 119th Cong., 1st sess., 2025, https://www.congress.gov/bill/119th-congress/senate-bill/1701/text. This bill, the Strategic Teams for Organized Response Mobilization (STORM) Act, indemnifies gig nursing platforms from liability for patient injury.96Senator Ted Budd (R-NC) introduced S. 1701 on May 8, 2025. See US Congress, Senate, Strategic Teams for Organized Response Mobilization Act, S. 1701, 119th Cong., 1st sess., 2025, https://www.congress.gov/bill/119th-congress/senate-bill/1701/text; Representative David Rouzer (R-NC-7) introduced H.R. 6539 on December 9, 2025, and the bill was referred to the House Subcommittee on Economic Development, Public Buildings, and Emergency Management on February 2, 2026. See US Congress, House, Strategic Teams for Organized Response Mobilization Act, H.R. 6539, 119th Cong., 1st sess., 2025, https://www.congress.gov/bill/119th-congress/house-bill/6539/all-actions. While little is known about the context in which this bill arose, its introduction echoes the significant pattern of nursing-platform legislation that we find at the state level. Gig nursing platforms are advancing a sweeping deregulatory campaign that threatens healthcare regulation, oversight, and accountability.

A Refusal of Carveouts

In the US, one state has taken steps to reject the deregulatory efforts of gig nursing platforms. New York passed a bill in 2025 that affirmatively recognizes gig nursing platforms as entities that must comply with the state’s healthcare staffing agency rules.97New York S.B. 3355, 2025–2026 Leg. Sess. (2025), https://www.nysenate.gov/legislation/bills/2025/S3355/amendment/original. As a result of the legislation, gig nursing platforms, like all healthcare staffing agencies, must register annually with the state, and report quarterly on the number of workers engaged, worker wages by job category, and details on wage and benefit expenditures.98New York State Department of Health, “Registration of Temporary Health Care Services Agencies and Health Care Technology Platforms,” https://www.health.ny.gov/facilities/staffing_agency/; New York State Department of Health, Registration of Temporary Health Care Services Agencies and Health Care Technology Platforms: 2024 Quarter 1 Data Report (2024), https://www.health.ny.gov/facilities/staffing_agency/docs/2024_q1_report.pdf. This law also does not define workers who use gig nursing platforms as independent contractors. It is a noticeable alternative to the deregulatory bills introduced in seventeen other states. Lobbying records show that three gig nursing platforms—Clipboard Health, Nursa, and Kare—that have been actively engaging with policymakers in New York in recent years are not operating in the state following enactment of the new platform regulations.99New York State Department of Health, “Registered Temporary Health Care Services Agencies, August 2025–July 2026,” https://www.health.ny.gov/facilities/staffing_agency/agency_list.htm.

Wisconsin: A Case Study

At a virtual meeting of an advisory group about workers’ compensation in Wisconsin earlier this year,100The group was the State of Wisconsin Department of Workforce Development’s Unemployment Insurance Advisory Council. One author of this brief was in attendance. See State of Wisconsin Department of Workforce Development, Notice of Meeting: Unemployment Insurance Advisory Council (IAC) Teleconference, February 19, 2026, https://dwd.wisconsin.gov/uibola/uiac/agenda/2026/20260219.htm. a debate unfolded about the premise of a proposed bill that would carve some healthcare workers out of workers’ compensation coverage in the state.101Author’s notes from State of Wisconsin Department of Workforce Development, “Unemployment Insurance Advisory Council (IAC) Teleconference, ” February 19, 2026, https://dwd.wisconsin.gov/uibola/uiac/agenda/2026/20260219.htm. The debate centered around gig nursing platforms and whether they necessitated a new regulatory structure. Are gig nursing platforms like Clipboard Health a unique business model in need of new regulations? Or are they just a tech-savvy version of healthcare staffing agencies, a familiar business model that is already governed by a set of existing regulations?

Wisconsin State Representative Rick Gundrum spoke at the outset of the meeting about why he had cosponsored a bill to establish a definition of gig nursing platforms as distinct from healthcare staffing agencies.102Wisconsin A.B. 794, 2025–2026 Leg. Sess. (2025), https://docs.legis.wisconsin.gov/2025/proposals/ab794; Wisconsin S.B. 768, 2025–2026 Leg. Sess. (2025), https://docs.legis.wisconsin.gov/2025/proposals/sb768. He focused less on how his bill carved gig nursing platforms out of state employment law and more on how gig nursing platforms are, in his eyes, so unique that they should be called “health care worker platforms.”

In the meeting, Gundrum argued that gig nursing platforms are not “traditional” staffing agencies and thus are not subject to the rules that govern those agencies. Nursing platform workforces, Gundrum said, are different in nature from those of staffing agencies because the majority of platform nurses supposedly (a) have other full-time jobs, and (b) want to be classified as independent contractors. How he knew this to be true is unclear, given that few public reporting requirements in US states would yield the quantity of active platform nurses or any information about their employment preferences or outside income. Gundrum did not cite any studies to buttress his claims.

Gundrum’s presentation was typical of how debates about gig nursing platforms often proceed with limited information about the actual operations of the platforms.103For example, a cosponsor of a gig nursing bill in Ohio acknowledged at a hearing that she did not know whether workers on these platforms are covered by any kind of workers’ compensation policy. See CitizenPortal, “Ohio Lawmakers Hear Testimony on Bill to Classify Platform-Based Health Workers as Independent Contractors,” June 3, 2025, https://citizenportal.ai/articles/6144633/ohio-lawmakers-hear-testimony-on-bill-to-classify-platform-based-health-workers-as-independent-contractors. Gundrum said he did not know how platforms ensure that nurses understand some of the specific hospital protocols for patient safety (which vary among facilities).104Author’s notes from State of Wisconsin Department of Workforce Development, “Unemployment Insurance Advisory Council (IAC) Teleconference.” Nor did he offer an answer, when asked, about whether an existing marketplace sells healthcare workers’ compensation policies for workers whom he proposed excluding from state coverage.

Gundrum was invoking the first policy strategy described above, which follows Uber’s playbook. He sought to define a new business category and then use that category as rationale for exemptions from state laws that set minimum wages, overtime pay, workers’ compensation, and unemployment insurance coverage. However, Gundrum did not maintain a coherent story about differences between healthcare staffing agencies and gig nursing platforms. When a union representative asked him directly to confirm if healthcare worker platforms follow the same model as a healthcare staffing agency, he unexpectedly replied: “Correct.”105Ibid.

By the end of the Wisconsin meeting, collective opposition was evident to Gundrum’s bill. As one participant put it: “The heart of this legislation creates another carveout and another test. Taking away the protections of workers […] is not the solution to the [healthcare staffing] challenge.”106Ibid.

Similar comments were voiced during a statehouse hearing on the bill that same month. For the Wisconsin AFL-CIO’s Stephanie Bloomingdale, the threats that gig nursing platforms pose to existing jobs at major hospital systems are real.107Bloomingdale’s questions and testimony reflect a growing focus on gig nursing platforms from traditional unions, including the Minnesota AFL-CIO, New York AFL-CIO, Minnesota Nurses Association, and, most notably, National Nurses United. In 2022, National Nurses United, a union, conducted a webinar on this issue. See National Nurses United, Uber for Nurses? The Gigification of Health Care, June 30, 2022, webinar, https://www.nationalnursesunited.org/gig-nursing. In 2023, the union was one of the first entities to identify the political parallels to Uber. See Michelle Grisat, “Request for Information: Automated Worker Surveillance and Management,” National Nurses United, June 29, 2023, https://www.nationalnursesunited.org/sites/default/files/nnu/documents/2023_OSTP_FRDOC_RFI_AWSM_National_Nurses_United_Comments.pdf. She characterized gig nursing platforms as “out-of-state corporations and tech giants” that “do not wish to follow our basic employment laws.”108Stephanie Bloomingdale, “In Opposition of SB 768,” Wisconsin State AFL-CIO, January 14, 2026, https://docs.legis.wisconsin.gov/misc/lc/hearing_testimony_and_materials/2025/sb768/sb0768_2026_01_14.pdf. She worries that these firms are giving healthcare facilities an easy way to union-bust—to reduce or fire existing employees and replace them with temporary staff.109A recent study found that workers were afraid to go on strike because of the possibility that the facility would “fire all of their full-time staff and hire temporary workers instead.” Suresh Naidu et al., Democracy Denied at the Bedside: Union Avoidance in Minnesota’s Nursing Home Sector, Columbia Labor Lab, March 5, 2026, https://laborlabcu.org/wp-content/uploads/2026/03/Union-Avoidance-Report-2026-03-05.pdf.

In fact, at the hearing, a certified nursing assistant named Jovan Miller recounted how she turned to platform work after the University of Wisconsin Hospital System reduced her number of hours.110It is not clear from Jovan’s testimony if she used the platform to work at the same hospital system or elsewhere. The elephant in the room was the impact of gig nursing platforms on existing healthcare jobs. Will gig nursing platforms lead to fewer stable employment opportunities or lower wages in the nursing profession? Will there be any legislative efforts to oversee and hold the health facilities accountable if they start laying off employed nurses to replace them with those recruited from gig nursing platforms?111For instance, on April 18, 2026, the Clipboard Health app showed 110 open nursing shifts at one for-profit Wisconsin facility for the period spanning April 20 through May 31, 2026.

The risks posed by new nursing platform legislation do not only concern workers. The Wisconsin bill offers minimal protections for healthcare facilities. The original language in the bill required gig nursing platforms to “maintain” occupational accident insurance for any work performed during a shift on the platform. An amendment removed this responsibility. Instead of “maintaining” insurance, the final bill simply requires platforms to “ensure” or “verify” the existence of a worker’s occupational accident insurance policy.112The amendment: “The worker platform ensures that workers are covered by occupational accident insurance or verifies that the workers are covered by worker’s [sic] compensation insurance applicable to any work performed during a work shift the worker schedules through the platform.” Wisconsin S. Amdt. 1 to S.B. 768, 2025–2026 Leg. Sess. (2025), https://docs.legis.wisconsin.gov/2025/related/amendments/sb768/sa1_sb768.

At the hearing on Gundrum’s bill, Eric Koch testified that it’s hard for long-term care facilities to make sure platform workers are “appropriately trained.”113Testimony on Senate Bill 768, Wisconsin Health Care Association and Wisconsin Center for Assisted Living (January 14, 2026\) (statement of Erik Koch), https://docs.legis.wisconsin.gov/misc/lc/hearing_testimony_and_materials/2025/sb768/sb0768_2026_01_14.pdf. Koch works for the Wisconsin Health Care Association and Wisconsin Center for Assisted Living, which represents more than five hundred long-term care facilities. He described how his members have experienced subpar service provision from app-based healthcare workers and, as a result, have been subject to “significant regulatory enforcement incidents.”114Ibid. Several private insurance interests (e.g., American Property Casualty Insurance Association, Sentry Insurance Company, and Wisconsin Insurance Alliance) also registered their opposition to the Wisconsin bill.

The future of Wisconsin’s platform nursing bill is unclear. The legislative session for the year has ended. But the Wisconsin case attests to how new definitions of gig nursing platforms—as distinct from healthcare staffing platforms—are being described in administrative meetings and statehouse hearings across the country. These definitions are often debated without full or accurate information about the workings of the platforms. The Wisconsin bill is indicative of the Uber-like carveout strategies that gig nursing platforms are deploying within the healthcare industry.

Conclusion

Almost everywhere we look, we find talk of AI-induced job displacement, which some call a “labor apocalypse.”115Jennifer M. Harris, “We Are Witnessing the Rise of a New Aristocracy,” New York Times, April 8, 2026, https://www.nytimes.com/2026/04/08/opinion/ai-wealth-inequality-jobs-investment.html. See also Ben Casselman, “Economists Once Dismissed the A.I. Job Threat, but Not Anymore,” New York Times, April 3, 2026, https://www.nytimes.com/2026/04/03/business/economists-once-dismissed-the-ai-job-threat-but-not-anymore.html; Te-Ping Chen, “AI-Displaced Workers Could Face Long Setbacks, Report Finds,” Wall Street Journal, April 6, 2026, https://www.wsj.com/economy/jobs/ai-displaced-workers-could-face-long-setbacks-report-finds-57ef1356; Alicia Wallace, “Report: Losing Your Job to AI Doesn’t Just Lead to Unemployment, It Leaves Lasting Scars,” CNN, April 7, 2026, https://www.cnn.com/2026/04/07/economy/ai-job-losses-long-term-effects; and Kathryn Palmer, “Which Jobs Are Most at Risk in the Age of AI?,” Inside Higher Ed, April 8, 2026, https://www.insidehighered.com/news/tech-innovation/artificial-intelligence/2026/04/08/which-jobs-are-most-risk-age-ai. Elon Musk says that “AI and robots will replace all jobs.”116Bernie Sanders, “AI Is a Threat to Everything the American People Hold Dear,” Wall Street Journal, April 2, 2026, https://www.wsj.com/opinion/ai-is-a-threat-to-everything-the-american-people-hold-dear-a3286459. The CEO of Anthropic predicts widespread unemployment.117Keach Hagey, “Anthropic CEO Says Government Should Help Ensure AI’s Economic Upside Is Shared,” Wall Street Journal, January 20, 2026, https://www.wsj.com/tech/ai/anthropic-ceo-says-government-should-help-ensure-ais-economic-upside-is-shared-1eab376c. The leader of the World Economic Forum warns that millions of people will be out of work as a result of AI.118Liz Hoffman, “BlackRock’s Larry Fink Says Davos Feels ‘Out of Step’ to Many,” Semafor, January 19, 2026, https://www.semafor.com/article/01/19/2026/davos-in-detroit-the-mountain-will-come-down-to-earth-larry-fink-says. OpenAI even released a set of policy recommendations to address the issue of impending mass unemployment.119Rachel Metz and Shirin Ghaffary, “OpenAI Advocates Electric Grid, Safety Net Spending for New AI Era,” Bloomberg, April 6, 2026, https://www.bloomberg.com/news/articles/2026-04-06/openai-advocates-electric-grid-safety-net-spending-for-new-ai-era.

Often missed in these discussions is how AI is affecting work today and inducing a mass degradation of work (rather than, for now, a mass displacement). Nowhere is the danger of an AI-propelled degradation of work more visible than in the rise of gig nursing platforms. The platforms’ algorithmic management systems—with their reliance on dynamic pricing, surveillance wages, and automated performance metrics—are transforming how workplaces function, with significant risks for workers and patients alike. Equally concerning is the pursuit of deregulatory policies by gig nursing platforms in statehouses across the country. Such policies could upend decades of laws and norms in the healthcare industry that guarantee public oversight, ensure worker protections, and safeguard patient care.

The campaign we outlined in this brief poses risks to communities and the economy at large. Last year, nursing was the largest source of job creation in the US.120Jeanne Whalen, “Nursing Is the Surefire New Path to American Prosperity,” Wall Street Journal, April 1, 2026, https://www.wsj.com/economy/jobs/nursing-jobs-pay-prosperity-b2769391. Today, it is the surest ticket to the middle class.121Ibid. The Wall Street Journal recently called the profession’s future “bright” and quoted a dean of a nursing school who stated that nursing is “AI proof.”122Ibid.

But if gig nursing platforms win their policy agenda, the future of the profession may not be so grand. Widescale adoption of gig nursing platforms may lead to fewer stable employment opportunities as healthcare facilities replace unionized and employed workers with gig workers.123For instance, on April 18, 2026, the Clipboard Health app indicated that eleven gig nursing assistants would work the same shift at a for-profit facility in Washington, D.C., on April 20, 2026; the app also posted openings on the same shift and day for five additional nursing assistants. AI-powered software that encourages nurses to bid against one another for shifts could lead to lower wages overall in the nursing profession, too.124On April 18, 2026, the Clipboard Health app described its “Quick Bid” shifts with the following language: “Quick Bid Shifts run for 5 minutes. You can choose the rate you’d like as a bid, and the lowest bid wins\! Bids are private. If you win, you’ll always earn at least what you bid. Quick Bid Shifts cannot be cancelled once booked. This auction ends in [a certain number of] minutes.” The app includes a header for these shifts with the verbiage “Bid to Win.” Given that many nurses are the primary breadwinner for their families,125Dionne Searcey, Eduardo Porter, and Robert Gebeloff, “Health Care Opens Stable Career Path, Taken Mainly by Women,” New York Times, February 22, 2015, https://www.nytimes.com/2015/02/23/business/economy/health-care-opens-middle-class-path-taken-mainly-by-women.html. the ripple-effects of a degradation of healthcare work could have far-reaching effects. Households may be further squeezed financially. Cities may collect fewer taxes and thus have less revenue with which to fund schools.

When the potential workforce harms of gig nursing platforms were raised at a Rhode Island hearing in early 2026, a lobbyist for Clipboard Health said: “We do not want to replace jobs.”126Rhode Island Capitol TV, House Committee on Health and Human Services: 1-29-2026, January 29, 2026, video, https://capitoltvri.cablecast.tv/show/11704 (%20https://capitoltvri.cablecast.tv/show/11704). Whether that is the case—and whether it matters what nursing platforms claim they want rather than what their deregulatory campaign is actually doing to the security of healthcare jobs—remains to be seen. Clipboard Health recently announced its intentions to expand its healthcare staffing work into home care.127Public Affairs Council, “Counsel, Legislation and Government Relations,” April 6, 2026, https://pac.org/job/counsel-legislation-and-government-relations. And its app now lists openings for teachers, paraprofessionals, child care workers, janitors, and chefs. The future of the economy could offer little of the stability that workers have fought so hard to win if platforms like Clipboard Health get to set the rules.

Acknowledgements

This report presents the research of Katie J. Wells, Maya Pinto, and Funda Ustek Spilda.

The authors would like to thank Kafui Attoh, Kate Brennan, Declan Cullen, Nina DiSalvo, Veena Dubal, Sally Dworak-Fisher, Terri Gerstein, Minsu Longiaru, John Marshall, Tim Newman, Laura Padin, Tina M. Park, Sandeep Vaheesan, and Sarah Myers West for their support of various stages of this project. The research team thanks Sylvie Binder, Ellen Schwartz, Emily Carter, and Caren Litherland for editorial and production assistance. Any errors, omissions, or other inaccuracies are the authors’ alone.

This report is dedicated to the memory of Alex Pretti.

About the Authors

Katie J. Wells is a Senior Fellow at the AI Now Institute.

Maya Pinto is a researcher and policy analyst whose areas of focus include digital labor platforms, AI-powered work management, and independent contractor misclassification.

Funda Ustek Spilda is a Senior Lecturer at the Department of Digital Humanities, King’s College London.

Appendix A: Table of State Policies

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Appendix B: Table of Platform Funders

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Appendix C: Primer on Gig Nursing

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