The National Labor Relations Board has decided that bargaining units combining employees who are jointly employed by a user employer and supplier employer and solely employed by the user employer do not require the consent of either employer. In so doing, the NLRB overturned its 2004 decision in Oakwood Care Center, 343 NLRB 659. Miller & Anderson, Inc., 364 NLRB No. 39 (July 11, 2016). The Board in Oakwood Care Centerdecided that in order for these employees to be combined in the same bargaining unit, all parties must consent.