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Advocacy

Comment Letter to State Board of Nursing on Pre-Draft Regulations Related to Pennsylvania’s Nursing Education Programs for Registered Nurses

August 20, 2014

Judith Pachter Schulder, Board Counsel
Pennsylvania State Board of Nursing
Bureau of Professional and Occupational Affairs
P.O. Box 2649 Harrisburg, PA  17105-2649

RE: Pre-draft Regulations—16A-5129: Nursing Education Programs

Dear Ms. Pachter Schulder:

The Hospital & Healthsystem Association of Pennsylvania (HAP), on behalf of its approximately 240 member hospitals and health systems, appreciates the opportunity to comment on the State Board of Nursing’s pre-draft regulations related to Pennsylvania’s nursing education programs for registered nurses.

HAP reviewed the pre-draft regulations with our Council for Health Professions Education, which includes the deans and directors of hospital-based nursing education programs. Based on this discussion, HAP has the following recommendations to improve or clarify the pre-draft regulations:

Under §21.951 Administrator, faculty and staff requirements

(a)(2), indicates that “full-time faculty members in the areas of practice encompassed within the curriculum, the maximum student-teacher ratio is 15 to 1 in clinical courses.”

Because each care setting is different, HAP recommends that the regulations not be so prescriptive with regard to student-teacher ratios. HAP recommends the language be amended to read, “student-teacher ratios in clinical courses should be consistent with patient safety standards outlined in facility policy and regulations.”

(b)(1)(v), indicates that “the administrator should possess the following credentials: no later than (10 years from the publication date of the final form regulation), the administrator of a professional nursing education program shall hold at least one graduate degree in nursing and an earned doctoral degree or have obtained a doctoral degree within 5 years of initial appointment and have experience in nursing practice, nursing education, and administration.”

HAP appreciates that the nursing board is seeking to establish the same standard for all nursing education program administrators, however, we are concerned about the timeframe for the program administrator to earn their doctorate. Specifically, we question whether five years provides enough time to earn the doctorate, considering the research that the candidate must engage in to complete the doctorate.

Therefore, HAP recommends the language be amended to read:

  • No later than 10 years following the date of publication of the regulation, all newly hired individuals prior to their appointment as a program administrator must be actively engaged in earning a doctoral degree whereby all course work is completed. The dissertation/research aspect of earning the doctoral degree must be completed within 5 years of their initial appointment as a full-time nursing education program administrator.

(b)(2)(iv), indicates that “faculty employed to teach a dietetic-nutrition course shall be currently licensed to practice dietetics-nutrition in the Commonwealth.” Questions were raised regarding if it is the board’s intent to require this type of course in the hospital-based nursing education program.

HAP is uncertain as to the board’s intent and respectfully requests that clarification be provided with regard to this.

Under §21.952 Faculty relationship with the controlling institution

(h), states that “full-time faculty of the nursing program may not carry responsible for administration, curriculum development or teaching for other types of educational programs, not may the nursing faculty be responsible student health services or first aid.”

HAP recognizes that there are typos in this paragraph; however, clarification is requested to understand the board’s intent.

HAP requests that the board’s intent be outlined to indicate that the board wants to ensure the faculty member is only responsible for the nursing education program in their primary job and that this provision would not hinder a person’s opportunity to have a secondary job.

Under §21.962 Content requirements

(b), states that “a nursing education program may use simulation in accordance with the clinical objectives of the course but shall not utilize simulation for an entire clinical experience with any patient population.”

In our discussion with our council members—whom all agreed that it would not be advantageous to replace a clinical with simulation for any patient population—they expressed how advantageous it would be to provide a one-credit simulation-only course that served as either a refresher course or a transition course based on what the nursing student learned in the previous semesters in order to identify gaps in the student’s retained knowledge.

It was outlined that by allowing schools to have a limited number of credits for a focused simulation course to serve as a supplement to the clinical experience from a previous clinical would provide a structure for the students that would positively influence and facilitate their educational experience.

HAP requests that the board consider the opportunity to allow for limited simulation courses.

HAP appreciates the opportunity to provide comments on this pre-draft rulemaking. If 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 me at (717) 561-5344.

Sincerely,

Paula A. Bussard
Senior Vice President
Policy and Regulatory Services

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