Comment Letter to State Board of Nursing on Pre-Draft Regulations Related to Pennsylvania’s Nursing Education Programs for Registered Nurses
Pachter Schulder, Board Counsel
State Board of Nursing
of Professional and Occupational Affairs
Regulations—16A-5129: Nursing Education Programs
Ms. Pachter Schulder:
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.
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.”
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.”
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.
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
(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
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
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.
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