Comment Letter to State Board of Nursing on Licensure General Revisions
Judith Pachter Schulder, Board Counsel
State Board of Nursing
of State, Office of General Counsel
RE: 16A-5125: General
Ms. Pachter Schulder:
Hospital & Healthsystem Association of Pennsylvania (HAP), on behalf of its
members, more than 225 acute and specialty hospitals and health systems,
appreciates the opportunity to comment about the State Board of Nursing’s
proposed regulations that seek to update regulatory provisions related to
registered nurse, practical nurse, and dietitian requirements for state
HAP reviewed the proposed
regulations with members of our Council for Health Professions Education, which
include the deans and directors of hospital-based nursing education programs.
Our comments reflect the input received from our council members.
agrees with the regulatory changes proposed by the board to ensure applicants
for the licensing examination demonstrate proficiency in English and that
applicants educated outside of the United States and Canada demonstrate program
equivalency in order to sit for the licensing examination.
HAP believes that
these provisions are particularly important to ensure patient safety.
most significant change proposed by the State Board of Nursing would be to
require graduates of registered nursing, practical nursing, and dietitian
programs to take the initial licensure examination within the first year of
graduation and to ultimately pass this examination within two years of
completion of a candidate’s education program.
During this two-year time
period, a candidate may take the licensing examination as many times as
believes that the board’s intent is to ensure the provision of quality and safe
care for Pennsylvania’s patients and supports these amendments in the proposed
HAP does have concerns with regard to the provision that requires the candidate
to complete a remedial plan developed by a board-approved program should the
candidate fail to pass the licensing exam in the prescribed two-year timeframe.
This requirement raises some questions that HAP believes need additional
consideration by the board:
Will the nursing education program
from which the student graduated be responsible for the remediation plan
or would it be the student’s responsibility to seek a program or site
where the services are offered?
HAP believes it would be unreasonable for
a school of nursing to be required to provide remediation services for
students who do not pass the licensing examination within two years of
graduation. This would cause an undue burden, particularly with regard to
ensuring there is adequate faculty to provide the remediation of each
It would be more appropriate for the student to be held
accountable for their continued efforts to remediate should they be
unsuccessful at passing the licensure examination rather than the school
from which they graduate.
Will the board be developing
criteria that outlines the curriculum that the remediation program would
have to adopt in order for the program to be provided to the population
needing the service? What would a remediation program be expected to
demonstrate as reasonable outcomes? How will quality be measured? What is
the board’s plan for follow-up and enforcement?
HAP believes it is
important for there to be standardization in this area in order for the
remediation programs to be effective.
The licensure examination protects
the public from those who cannot demonstrate minimal competency. If there
are no remedial programs or services available, what would be the
HAP believes there may be some legal ramifications
as a result of this requirement that may need to be addressed.
appreciates the opportunity to comment about these proposed regulations on
behalf of its Council for Health Professions Education, and seeks the board’s
input with regard to the concerns that have been raised.
you have any questions about HAP’s comments, please feel free to contact Mary Marshall, director, workforce
and professional services, at (717) 561-5312 or contact me at (717) 561-5344.
and Regulatory Advocacy