Employers are obligated by the NLRA to bargain in good faith over issues of wages, hours, and other terms and conditions of employment (Szcepanski, 2003a). The latter bargaining focus, terms and conditions of employment, has taken on a prominence over the other two, however, in the current nursing shortage environment. Nurses are reporting that while wages and benefits are important, these are not the primary reasons for turning to unions and CB (McGrath, 1996; Steltzer, 2001). More important is the ability to ensure an environment that will allow nurses to practice in a manner conducive to achieving the best possible patient health outcomes (Darr et al., 2002). Consequently, in addition to wages and benefits, common subjects of agreements negotiated in CBAs include: