|
Comment Letter to Pennsylvania Board of Nursing on Continuing Education for Professional Nurses
Regulatory Advocacy
Last Updated: 5/25/2007
May 25, 2007
Ann Steffanic, Board Administrator
Pennsylvania State Board of Nursing
Bureau of Professional and Occupational Affairs
P.O. Box 2649
Harrisburg, PA 17105-2649
RE: 49 PA.CODE CH. 21—Continuing Education for Professional Nurses
Dear Ms. Steffanic:
The 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 provide comments on the State Board of Nursing’s draft regulations regarding continuing education for professional nurses.
HAP appreciates the Board of Nursing’s efforts to develop the most flexible and comprehensive continuing education requirements that allow registered nurses to complete the continuing education for their licensure renewal in the most prudent way possible. HAP believes that the Board of Nursing has made substantial improvements in several existing provisions of the regulations, including:
- §21.29(c), which codifies the Board’s efforts to allow for online license renewal. HAP has strongly supported the Board’s efforts to streamline license renewal and other types of application processing, including the processing of temporary practice permits for new graduates.
- §21.29(d), which eliminates the requirement that the licensee’s current employer must retain the display portion of the renewed license. On different occasions in the last several years, HAP has requested that the Board amend this requirement. HAP had previously indicated that the Pennsylvania State Board of Nursing does not have the authority to regulate employers and therefore, HAP urged the Board to delete this requirement. In recent years, the Board has recognized the increased ease of creating fraudulent documents and indicated that the most accurate and current portrayal of current licensure status can only be achieved through use of the state’s online licensure verification system.
HAP supports the overall direction taken by the Pennsylvania State Board of Nursing in the development of these proposed regulations. HAP believes that the Pennsylvania State Board of Nursing has taken great effort to ensure that practicing professional registered nurses have flexibility in meeting the continuing education requirements. Specifically, HAP appreciates that the Board has not limited the number of continuing education hours that can be obtained through distance learning activities, and that the Board has recognized that Pennsylvania’s accredited and licensed general acute care and specialty hospitals offer professional learning opportunities for registered nurses that can be used to satisfy the continuing education requirements. This recognition makes obtaining continuing education requirements more accessible and affordable to nurses licensed in the Commonwealth. HAP believes that the Pennsylvania State Board of Nursing has an even greater opportunity to recognize those activities that foster professional growth and development. HAP believes that the Board should consider these other opportunities, since recognition of these types of activities by the Board could serve to spur interest and involvement in such activities, all of which serve to improve the quality and safety of nursing care delivered to the citizens of Pennsylvania. HAP has provided some recommendations for consideration by the Board, and would strongly recommend that the Board consider continuing education regulatory language already adopted by the states of New Jersey, Delaware, and Ohio – all states that require comparable completion of continuing education as a condition of licensure. HAP and its member hospitals and health systems believe that it is extremely important for the Board to create and seek opportunities to speak directly to the professional registered nurses that it regulates to impress upon them the importance of complying with the continuing education requirements. While employers can assist nurses in obtaining continuing education, it is incumbent upon the professional nurse to complete the requirements and maintain a record of those activities that he or she has pursued to meet the requirements. Professional registered nurses must be made fully aware of these new requirements and their accompanying professional responsibility and accountability in completing the requirements to retain the privilege to practice as a nurse in the Commonwealth. HAP has attached its specific recommendations for consideration by the Board. HAP looks forward to working with the Pennsylvania State Board of Nursing to implement the provisions of Act 58 of 2006, which required continuing education for professional registered nurses. HAP also requests that the association be notified when the Board submits the final-form regulations to the House Professional Licensure and Senate Consumer Protection and Professional Licensure Committees, as well as notice of any amendments or changes to the proposed version. If you have any questions about HAP’s comments, please feel free to contact me at (717) 561-5308 or by email at lgleighton@hapoline.org.
Sincerely,
LYNN G. LEIGHTON
Vice President
Professional & Clinical Services
|
