Comment from Nucleus Healthcare

Jessica Looman Acting Administrator Wage and Hour Division U.S. Department of Labor Re: Proposed Changes to Prevailing Wage Calculations for H1B, H1B1, and PERM Programs Dear Ms. Looman, I am writing to express serious concern regarding the Department of Labor’s proposed changes to prevailing wage calculations for H1B, H1B1, and PERM programs and the unintended consequences these changes may have on the healthcare industry, particularly hospitals and healthcare systems already facing severe workforce shortages. I am the CEO of Nucleus Healthcare, a Pennsylvania based, women owned healthcare workforce company. We partner directly with hospitals and healthcare systems across the United States to address persistent nursing shortages by placing internationally educated registered nurses into long term workforce roles. Our model was specifically designed to reduce reliance on high cost agency staffing, stabilize workforce continuity, improve retention, and lower overall labor costs for healthcare systems operating under significant financial pressure. We fully support fair and competitive wages for all healthcare professionals. However, the proposed increase in prevailing wage calculations would create substantial downstream consequences for hospitals, caregivers, and patient access to care. Importantly, prevailing wages have already increased meaningfully in recent years in many markets. For example, in New Jersey, Level II prevailing wages for registered nurses increased significantly in 2025. Our company adjusted our business model accordingly and absorbed those increases to continue supporting hospitals struggling with staffing shortages. Under the proposed methodology changes, Level II prevailing wage rates in certain markets could increase an additional 25 to 35 percent. In practical terms, a nurse currently required to be paid approximately $38 to $40 per hour could potentially require wages approaching or exceeding $50 per hour under the new framework. These are employee pay rates, not bill rates. At those levels, hospitals face internal wage equity pressures across their entire nursing workforce, making long term international workforce programs financially difficult to sustain. The likely outcome is continued reliance on significantly more expensive agency staffing solutions and reduced ability for hospitals to build stable, long term workforce pipelines. The healthcare industry is fundamentally different from many other industries impacted by this proposal. Hospitals cannot simply reduce demand for labor. Staffing shortages directly impact patient access to care, nurse burnout, closed beds, delayed treatment, and community health outcomes. Rural hospitals and critical access hospitals will be disproportionately affected. Attached is a national prevailing wage analysis prepared using official Department of Labor OFLC wage data. The workbook analyzes prevailing wage trends across 528 healthcare labor markets from 2021 through 2026 and demonstrates that substantial prevailing wage increases have already occurred in many markets prior to this proposal. Summary of attached analysis: • 2025 through 2026 data includes 528 of 528 labor markets nationwide • 2021 through 2025 historical analysis includes 498 of 528 markets annually • Analysis includes year over year wage increases, total dollar increases, percentage increases, and largest single year increases by market • Data sourced directly from official Department of Labor OFLC prevailing wage files using metro level geographic data • Crosswalk methodology applied where BLS market definitions changed between years to preserve historical continuity The attached analysis demonstrates that prevailing wages in healthcare markets have already increased materially in recent years without the additional percentile restructuring proposed under this rule. I respectfully ask the Department to carefully evaluate the impact this proposal may have on healthcare workforce stability and patient access to care and to consider healthcare specific accommodations for critical shortage occupations such as nursing. I would welcome the opportunity to discuss these concerns further and provide additional operational and market data from healthcare systems directly impacted by these proposed changes. Thank you for your time and consideration. Warmly, Lynn Bruder CEO Nucleus Healthcare 610.329.7328