On Feb. 20, 2015, Peter Sung Ohr, regional director of the National Labor Relations Board (NLRB), issued an unexpected decision, ruling that scholarship players on Northwestern University's football team were employees under the National Labor Relations Act (NLRA), and as such, had the right to form a union. While only applicable to private universities, the decision sent shockwaves through college athletics. If upheld, scholarship football players would be able to collectively bargain the terms of their employment, such as compensation, working hours, health care benefits, and paid time-off. This of course would not only directly conflict with the National Collegiate Athletic Association (NCAA) rules prohibiting pay for play, but significantly undercut the entire concept of amateurism in college sports.