The Attorneys General of California, Colorado, and Nevada yesterday announced a $2.9 million settlement with HCA Healthcare and its staffing arm, HealthTrust Workforce Solutions, resolving allegations that the hospital giant imposed unlawful training‑repayment agreements on new nurses. The agreement follows a multistate probe conducted by the attorneys general in partnership with the Consumer Financial Protection Bureau.
The background: Between 2017 and April 2023, HCA required newly hired registered nurses to enroll in its Specialty Training Apprenticeship for Registered Nurses residency program as a condition of employment. Although the program was advertised as career‑launching clinical training, participants were already licensed to practice and the program did not provide any education required for licensure. Entry‑level nurses who left HCA within two years faced “training repayment agreement provisions” (TRAPs) obliging them to reimburse HCA up to the full stated value of the program — about $4,000 — which was prorated by month short of the two‑year mark. If a nurse departed early, HCA frequently sent the resulting balance to a third‑party debt collector, or withheld it from the nurse’s final paycheck .
California law requires employers to cover the full cost of any training they mandate for direct patient‑care staff, and federal consumer‑protection laws prohibit unfair or abusive debt practices. After a years‑long investigation, the California AG’s office concluded that HCA’s TRAPs unlawfully saddled nurses with employer‑driven debt and unfairly trapped them in jobs they might otherwise have left.
The claims: The California complaint alleges that HCA’s use of TRAPs violated multiple state and federal laws, including:
- Unfair Competition Law (Bus. & Prof. Code § 17200 et seq.) by imposing and collecting on prohibited training debts and failing to indemnify nurses for expenses incident to their duties.
- Consumer Financial Protection Act by engaging in abusive practices by interfering with nurses’ understanding of debt terms through late or incomplete disclosures, and in unfair practices by referring unenforceable debts to collectors .
- California Consumer Financial Protection Law by marketing and administering TRAPs as consumer financial products without proper disclosure or consent.
- Labor Code Sections 2802 and 2802.1 by forcing nurses to pay for employer‑required training that did not further their licensure and was not undertaken voluntarily.
Under the settlement, HCA will provide full restitution to affected California nurses, approximately $83,000 in refunds, void all outstanding TRAP debt, pay $1.16 million in state penalties, and agree to a permanent ban on imposing or collecting any TRAPs on nurse employees.
