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Letter to the BRN: Amendments to the California Code of Regulations, Title 16, Division 14, Article

This is a letter sent to the California Board Registered of Nursing from the Members of the QUAD Council on January 20, 2022.


California Board of Registered Nursing

1747 Market Street, Suite 150

Sacramento, CA. 95834

Re: Amendments to the California Code of Regulations, Title 16, Division 14, Article 3

Dear Board Members:

The Quad Council consists of key professional leadership organizations in California including ANA/C, ACNL, CACN and COADN —North and South. It serves as a platform to identify and discuss issues confronting the profession and professional education in the state.

We were informed of the hearing to be held on January 20, 2021, to discuss amendments to the California Code of Regulations, Title 16, Division14, Article 3. We have reviewed the proposed revisions and we offer the following concerns for your consideration.

Fairness and Equity

  1. There is already a process for programs that are currently approved. Why make approved programs in good standing go through the same process as an entirely new program with no outcomes or history of BRN compliance?

  2. While the state is experiencing a critical nursing shortage, the proposed process will impede the ability of institutions of higher education to address the workforce needs of their communities of interest by delaying approval of new sites with workforce needs.

  3. The Executive Director alluded to this upcoming change at the last BRN meeting. We searched the web site to find this proposed change. How are stakeholders notified about changes like this that may impact their strategic plans and budget?

  4. Approved programs already submit periodic self-studies. These extra steps and layers are duplicative. Why add additional time and work for programs who are already in good standing?

Financial Risks and Costs

  1. The site visit mentioned is ill-defined with respect to scope of evaluation. Does the new site need to be student ready before the NEC allows the proposal to move toward Board approval? If so, we estimate costs for a site with classrooms, labs, simulation, equipment, and technology to be greater than $1 million. This poses substantial risk with no guarantee of approval.

    1. Also, the ELC/BRN often suggests substantially lower enrollment numbers than requested, even when the program provides evidence to support the enrollment request. This unknown variable makes it impossible to determine whether an expansion can be financially viable.

  2. The proposed change causes financial burden to currently approved programs since investment (fee, salaries, site build) will not receive a return (tuition) for ~ 3-4 years.

    1. This may cause a disproportionate number of wealthy programs to expand, while limiting programs in need of financial growth opportunities.

  3. The cost of filing a major curriculum change vs. a new program approval is substantial ($40K vs. $2.5K). This will be an obstacle for colleges and universities to expand, given there is no guarantee of approval.

Time Constraints

  1. The current process involves one submission, and one approval cycle with the NEC, ELC and Board (about 6 months). The proposed process involves three submissions and two approval cycles with the NEC, ELC and Board. How long does this process take? A review of Board actions indicates this is about 3 years.

  2. A significant amount of the content required in the feasibility study is already on record for approved programs. The remainder of the content is already part of the current curriculum change process for a new site for an approved program. Why is this duplication necessary?

Other areas of concern:

  1. We have shared concerns regarding the BRN promulgating regulations ahead of the Sunset review process. There are also concerns regarding additional cost burden on the existing programs.

  2. We have previously submitted documents that outline the importance of the BRN aligning with accreditor standards. Yet we have not seen any movement toward that alignment and this action is contrary to that alignment.

We respectfully submit these concerns for your serious and sincere consideration as you discuss the proposed action.

Respectfully Submitted:

Members of the QUAD Council

American Nurses Association\California:

Dr. Marketa Houskova, Executive

Dr. Anita Girard, President

Association of California Nurse Leaders:

Dr. Kimberly C. Long, Chief Executive Officer

Ms. Ellen Zoschak, 2022 President

Dr. Dale Beatty, 2023 President Elect

Dr. Mary Foley, ACNL Academia

California Association of Colleges of Nursing:

Dr. Karin Lightfoot, President

Dr. Ron Norby, President Elect

Dr. Mary Wickman, Immediate Past President

California Organization of Associate Degree Nursing:

Dr. Lynette Apen, President-North

Dr. Tammy Vant Hul, President-South

Health Impact:

Dr. Garrett Chan, CEO


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