The term Pro Re Nata (PRN) describes a contingent employment status prevalent in the healthcare industry, meaning “as needed.” These nurses, technicians, and assistants fill staffing gaps on a temporary or unpredictable basis across various units or facilities. PRN staff are generally eligible for overtime compensation, subject to specific federal and state regulations. Eligibility depends entirely on how their hours are tracked and aggregated within the employer’s defined workweek.
Defining the PRN Employee Status
The PRN designation signifies that an individual is employed on a casual or reserve basis, called upon only when patient volume or staff shortages require it. Despite the unpredictable nature of the work schedule, PRN individuals are almost universally classified as W-2 employees of the hiring facility or system. This W-2 status subjects them to standard employment laws, including those governing minimum wage and overtime, meaning they are not independent contractors.
Most PRN roles are hourly positions, legally categorized as non-exempt. This classification is foundational for determining overtime eligibility, as non-exempt employees are protected by federal wage and hour laws. This holds true regardless of the employee’s profession, whether they are a registered nurse or a certified nursing assistant.
Understanding Federal Overtime Law
The foundation for premium pay in the United States is the Fair Labor Standards Act (FLSA), which establishes the national standard for minimum wage and overtime. The FLSA mandates that non-exempt employees receive compensation at a rate of one and one-half times their regular rate of pay, commonly called “time and a half.” This elevated rate is required for any hours worked beyond 40 in a single, defined workweek.
Federal law grants employers the discretion to establish their own workweek, which is a fixed and regularly recurring period of seven consecutive days. This workweek does not have to align with the calendar week, but once established, it must be used consistently for payroll purposes. The determination of whether overtime is due is reset at the start of each new workweek, independent of any preceding or following pay period.
The FLSA does not stipulate that an employer must pay overtime for hours worked on weekends, holidays, or simply because a shift exceeds eight hours. The only federal requirement is the weekly 40-hour threshold. This standard applies to all non-exempt employees, regardless of whether they are full-time, part-time, or PRN staff.
How Overtime is Calculated for PRN Staff
Applying the FLSA to the sporadic schedule of PRN staff requires meticulous tracking by the employer within the defined workweek. The central principle governing this calculation is that all hours worked for a single employer must be aggregated. This aggregation applies regardless of the department, unit, or facility within that system where the hours were performed. For example, if a PRN nurse works 20 hours on the cardiac floor and 25 hours in the emergency department for the same hospital network, the network must aggregate those hours to 45.
In this scenario, the network owes the employee five hours of overtime pay at the time-and-a-half rate. If the employee is paid different hourly rates for different units, the employer must use a specific weighted average calculation to determine the “regular rate of pay” for the overtime hours. The employer bears the legal burden to maintain accurate records of all hours worked and prevent underpayment of premium wages.
The unpredictable nature of PRN scheduling means employees often work shifts that cross over the employer’s established workweek boundaries. For example, a shift might begin at 7:00 PM on Friday and end at 7:00 AM on Saturday, spanning two separate payroll workweeks. The employer is responsible for correctly dividing the shift hours into the respective workweeks for accurate calculation, ensuring no hours are overlooked when determining the 40-hour threshold.
The Impact of State Laws on Overtime Eligibility
While the FLSA sets the federal floor for compensation, several states have enacted laws that provide employees with greater protections. This often results in overtime eligibility sooner than the federal 40-hour weekly standard. The most relevant state-level difference for PRN healthcare workers is the concept of daily overtime, which mandates that premium pay begins after a certain number of hours are worked in a single day, regardless of the total weekly hours.
For example, states such as California and Alaska require time-and-a-half pay for hours worked beyond eight in a single workday, which is relevant for common 12-hour healthcare shifts. In these jurisdictions, a PRN employee working one 12-hour shift would immediately earn four hours of daily overtime, even if they work no other hours that week. These state rules operate independently of the federal weekly threshold and are applied first when calculating payment.
Some state laws also require double-time pay for hours worked beyond 12 in a single day or for work performed on a seventh consecutive day. These state provisions supersede the FLSA when they offer greater benefits to the employee. Therefore, a PRN employee’s eligibility for overtime is determined by whichever law, federal or state, provides the higher compensation.
Common Misconceptions About PRN Pay
A frequent misunderstanding among PRN staff is the belief that hours worked for separate, unrelated healthcare facilities must be combined for overtime purposes. The FLSA’s aggregation requirement only applies to hours worked for a single employer or closely affiliated enterprises. This means a PRN employee can work 30 hours for Hospital A and 30 hours for the unrelated Hospital B in the same week without any overtime due from either facility.
Another misconception involves the employment classification, where staff sometimes mistakenly believe their contingent status automatically makes them independent contractors. Because PRN workers typically use the facility’s equipment, follow its protocols, and are directed by its supervisors, the Department of Labor generally classifies them as W-2 employees, not 1099 contractors. Employees should document their scheduled hours and promptly raise questions with Human Resources if they suspect an error in their compensation calculation.