Attorney General Brian L. Schwalb today announced that the Office of the Attorney General (OAG) successfully resolved two separate investigations into suspected workplace rights violations involving the use of unlawful training repayment agreement provisions—known as TRAPs—that harmed nurses at George Washington University Hospital (GWU Hospital) and preschool teachers at The Hill Preschool.

OAG’s investigation revealed that both the hospital and the preschool required their employees to agree to illegal contract provisions that required them to pay their employers back for training and other costs if they resigned before the end of their contract term. In the District, absent statutory authorization, employers can only require employees to repay the cost of training if that training primarily benefits the workers, for example, by providing a portable certification or credential. Under the terms of separate settlement agreements, GWU Hospital and The Hill Preschool will pay a total of more than $127,000 to impacted workers and the District and have agreed to reform their workplace practices.

“These TRAP agreements restricted the job mobility of nurses and preschool teachers, financially penalizing them for choosing to change jobs,” said Attorney General Brian Schwalb. “The Office of the Attorney General will continue to fight to make sure that workers’ rights are protected and that law-abiding businesses can compete on a level playing field.”

OAG’s Settlement with George Washington University Hospital

GWU Hospital is a 395-bed medical center providing care in downtown DC. OAG’s investigation into District Hospital Partners, LP (which does business as GWU Hospital), uncovered evidence that from January 1, 2020 through July 1, 2023, the hospital subjected certain nurses who were primarily newly-licensed or recent graduates to a TRAP that required them to repay “training” costs of up to $7,500 if they resigned prior to the completion of a two-year commitment. The hospital enforced this provision through unlawful deductions from nurses’ final paychecks and through requests for payment. The hospital referred certain nurses to collections for failing to make repayments under the TRAP.

OAG’s investigation confirmed that the nurses subject to this TRAP received only the on-the-job training typical of any nursing role, not a portable credential or standalone certification. At least 12 nurses paid the hospital nearly $35,000 under these agreements, and another 27 nurses were referred to collections for failing to pay the money demanded.

OAG alleges that these TRAPs violated the District’s antitrust laws and ban on noncompete agreements because they deterred workers from seeking other employment, and that the repayments nurses made were unlawful deductions from the wages they earned in violation of the District’s wage and hour laws. During OAG’s investigation, GWU Hospital stopped requiring new nurses to sign TRAP agreements with training repayment provisions.

Under the terms of a settlement agreement, GWU Hospital will:

• Pay $96,998.40 in restitution and damages to 39 harmed nurses.
   
• Pay $15,000 in penalties to the District.
   
• Notify impacted employees that the contract clause requiring repayment is void and unenforceable.
   
• Rescind all open collections efforts related to these contract provisions.
   
• Notify the District if it seeks to institute a similar training repayment program for employees within the next three years.

A copy of the settlement agreement is available here.

OAG’s Settlement with The Hill Preschool

The Hill Preschool is a District non-profit that provides early childhood education for children ages two through five in the Capitol Hill neighborhood. OAG’s investigation uncovered evidence that from 2022 through the present, the school required its preschool teachers to sign contracts containing TRAPs that would force them to repay the school for a variety of costs—including any bonuses they earned, money the school spent to train them or provide staff development, and more—if they resigned before the end of their year-long contract term. When teachers did resign before their contract term, The Hill Preschool deducted these “repayments” from their final paychecks.

OAG alleges that the use of these TRAPs violated DC’s local antitrust laws and ban on non-compete agreements because they deterred workers from seeking other jobs. OAG also alleged that the deductions from teachers’ final paychecks violated DC’s wage and hour laws.

Under the terms of an agreement with the District, The Hill Preschool will:

• Pay $11,712.50 to impacted preschool teachers.
   
• Pay $4,250 in penalties to the District.
   
• Stop using the improper contract clauses for current and future employees and agree not to enforce the clauses in any existing contracts.
   
• Provide notice to all current and former impacted employees that the contract clause requiring repayment is void and unenforceable.

A copy of the settlement agreement is available here.

These matters were handled by Assistant Attorneys General Sarah Michael Levine, Jude Nwaokobia, and former Assistant Attorney General Morgan Sperry, with assistance from Data Scientist Aziza Talajawala.

OAG’s Efforts to Protect Workers  

OAG’s Workers’ Rights and Antifraud Section is dedicated to fighting wage theft, protecting District workers, and ensuring that businesses in the District compete on a level playing field. Since AG Schwalb became the District’s elected, independent Attorney General in January 2023, OAG has secured more than $20 million for workers and the District. In total, since gaining independent wage theft enforcement authority in 2015, OAG has secured over $35 million by investigating and bringing enforcement actions against employers who violate District law. OAG’s wage theft enforcement efforts have focused on industries with high populations of vulnerable workers, such as construction, restaurants and hospitality, healthcare, and the gig economy. Learn more about OAG’s efforts to uphold workers’ rights over the last year in OAG’s 2025 Labor Day Report.  

How to Report Workplace Rights Violations

Workers who believe that their rights have been violated, or that they have experienced wage theft or other wage and hour violations, can contact OAG by calling (202) 724-7730 or emailing workers@dc.gov or trabajadores@dc.gov.