The Labour Court will today hear submissions from unions over the Health Service Executive's (HSE) recruitment freeze.
The health service unions argue that the HSE breached the terms of the social partnership agreement, Towards 2016, by the way it announced the cost-cutting measures last year.
Under the terms of Towards 2016, employers are required to inform and consult staff over issues that affect their working lives.
The HSE Employers Agency has rejected the unions' claim.
The joint complaint to the Labour Court is being submitted by Impact, Siptu, the Irish Nursing Organisation, the Irish Medical Organisation and a number of other unions.
An Impact spokesman claimed today the HSE has imposed "even tighter restrictions" since it said at the end of December it had lifted its three-month recruitment embargo.
Impact said a HSE circular issued earlier this month "effectively abolished" vacant positions that were unfilled when last year's recruitment freeze was imposed. Jobs that became vacant during the three-month freeze are also to go unfilled.
The union said that according to the circular, the HSE will only filling vacancies that arise after January 1 st. The only vacancies that arose before this date that will be considered for filling are "critical front-line vacancies", Impact said.
"If the Government thinks health workers are annoyed about benchmarking, they should brace themselves for a real wave of anger over staffing in hospitals and community health services," IMPACT national secretary Kevin Callinan said.
"This bizarre and unworkable new policy is hurting patients and service users, while placing intolerable burdens on workers. Posts are being suppressed even if they are within budget, within complement and approved as necessary by the HSE as recently as last autumn," he said.