Przybylo, Kerry (LARA)  
From:  
Sent:  
To:  
BPL-BoardSupport  
Wednesday, September 27, 2023 10:57 AM  
Przybylo, Kerry (LARA)  
Subject:  
Attachments:  
FW: Open Comment Period for Nursing Administrative Rules Draft  
image001.png  
From: Jennifer Avery <javery10@emich.edu>  
Sent: Wednesday, September 27, 2023 10:09 AM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Re: Open Comment Period for Nursing Administrative Rules Draft  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Hello Board Support-  
I have no objections or proposed changes to the proposed language updates, thank you for providing the opportunity  
for comment.  
Jen  
Jennifer Sjostedt Avery PhD, RN, GNP-BC  
Interim Director, School of Nursing  
Eastern Michigan University  
On Tue, Sep 26, 2023 at 8:25ꢀAM Przybylo, Kerry (LARA) <PrzybyloK@michigan.gov> wrote:  
Dear Directors of Nursing:  
The public hearing to receive comment on the nursing administrative rules is set for October 16, 2023.  
Please review the revised changes. If you wish to make a comment you may do so in one of two ways: In person or in  
writing by sending your comment to BPL-BoardSupport@michigan.gov by 5:00 p.m. on October 16, 2023.  
The rules committee has worked hard to provide better clarity. However, if you have suggested changes, please  
provide the proposed language for adoption.  
1
Warm regards,  
Kerry  
Kerry Ryan Przybylo, JD  
Manager, Boards and Committees  
Bureau of Professional Licensing  
Department of Licensing and Regulatory Affairs  
611 W. Ottawa Street  
Lansing, Michigan 48909  
(517) 342-4971 (cell)  
The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.  
2
Przybylo, Kerry (LARA)  
From:  
Sent:  
To:  
BPL-BoardSupport  
Monday, October 2, 2023 8:41 AM  
Przybylo, Kerry (LARA)  
Subject:  
FW: Comments/questions  
Is this something you can answer regarding nursing schools or is it a rules thing for Jennifer?  
Thank you,  
Stephanie Wysack  
Departmental Technician  
Boards and Committees Section  
Bureau of Professional Licensing  
Michigan Department of Licensing and Regulatory Affairs  
Phone: 517-241-7500  
From: Lauren Foltz <laurenfoltz3@gmail.com>  
Sent: Sunday, October 1, 2023 5:36 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Comments/questions  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Dear BPL,  
R 338.10303 pertains to initial program approval. Clarification about the impact on all existing  
nursing education programs within a 50-mile radius is needed. Based on the documentation  
submitted by programs seeking initial approval and the meeting minutes, it seems as though a  
survey is how this rule is satisfied. The rule should specifically state that a survey is required  
with some suggested questions specifically related to the impact on sharing clinical  
sites. Particularly, a question included in the survey should be:  
1. What is your plan to collaborate with nearby schools of nursing to ensure adequacy  
of clinical placements?  
Sincerely,  
1
Lauren Foltz  
2
Przybylo, Kerry (LARA)  
From:  
Sent:  
To:  
BPL-BoardSupport  
Friday, September 29, 2023 10:52 AM  
Shaltry, Jennifer (LARA)  
Cc:  
Przybylo, Kerry (LARA)  
Subject:  
FW: Comment on rules update  
From: Leefers, John P. <John.Leefers@corewellhealth.org>  
Sent: Friday, September 29, 2023 10:51 AM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Comment on rules update  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Hello,  
A fellow Nurse Educator shared with me the following informafion:  
“Quick MIBON Rules update: the nursing rules are open for comment on revisions currently...there are proposed  
changes, which include allowing the implicit bias training to count toward the 25 CE hours requirement, newly licensed  
nurses need to do CE for the first licensing cycle, and 120 hours of precepfing only counts for 1 contact hour (instead of  
5)”  
I have a comment one of these proposed changes:  
I am opposed to newly licensed RNs being required to complete confinuing educafion in their rst cycle. New  
grad orientees who hire into the ICUs I serve will oꢀen have 100-130 hours of class fime to prepare them for  
their role. I recognize that ICU seꢁngs are outliers for the amount of in class non-CE learning a new nurse must  
complete… but I also believe that all new nurses are going to go through some kind of training program that  
transforms them from a nursing student to a producfive professional. The purpose of contact hours is to  
promote professional growth and expand the knowledge set of our colleagues. Brand new nurses get plenty of  
that already. The addifional burden of complefing sancfioned contact hours seems unnecessary considering the  
great amount of learning and professional growth that new RNs are obligated to by the nature of employment.  
Perhaps an compromise would be an exempfion for RNs who become employed in direct care.  
Thank you,  
John Leefers, BSN, RN, CCRN-K  
He/Him/His  
Adult Critical Care Nurse Educator  
Nursing Practice and Development  
517.648.7161 Cell  
corewellhealth.org  
1
1840 Wealthy St SE  
Grand Rapids, MI 49506  
Office # 1H-65  
MC: 465  
As a nursing professional development practitioner, I facilitate the development of nurses and allied health  
personnel from novice to expert. I achieve this by being a learning facilitator, change agent, leader, mentor,  
champion of scientific inquiry and partner for practice transitions.  
2
Przybylo, Kerry (LARA)  
From:  
Sent:  
To:  
BPL-BoardSupport  
Monday, October 16, 2023 7:05 AM  
Shaltry, Jennifer (LARA); Przybylo, Kerry (LARA)  
FW: Comments on Nursing Administrative Rules Draft Revisions  
Subject:  
From: Meringa, Joshua M.(Josh) <josh.meringa@corewellhealth.org>  
Sent: Friday, October 13, 2023 4:22 PM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Comments on Nursing Administrative Rules Draft Revisions  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Hello Board of Nursing Rules Commiꢀee,  
Please accept my comments below on the Draꢁ Nursing Administrafive Rules that have been proposed and are  
scheduled for a public hearing on Monday, October 16.  
1. R 338.10601 (5)  
Please keep this rule intact. Eliminafing this rule would begin requiring newly licensed Michigan nurses to  
complete all confinuing educafion requirements during their inifial licensing cycle, which for most would be their  
rst 2 years in pracfice as new grad nurses. Most newly licensed nurses will have recently completed not only  
their formal nursing educafion programs, but also have studied for and successfully taken the NCLEX. During  
this fime most newly licensed nurses will complete rigorous orientafion and onboarding programs, which  
include hands on training and educafion as well as competency validafion for independent pracfice. Many  
newly licensed nurses will also parficipate and complete nurse residency programs, which have educafional and  
professional development components spanning the first year (or two) in pracfice. Due to this extensive  
educafion experience that most newly licenses nurses will have recently parficipated in, I would suggest that the  
Board of Nursing confinue to excuse newly licensed nurses from the general confinuing educafion requirements  
during their inifial licensing period. My understanding is that way back when, the rafionale for newly licensed  
nurses (new grads) not being required to complete confinuing educafion hours was based on the fact that they  
have recently completed a rigorous nursing educafion program within the past few years and should be up to  
date on current nursing pracfice standards as then enter the workforce. The purpose of confinuing educafion is  
for nurses to maintain confinued competence in a rapidly changing healthcare environment. I would argue that  
our newly licensed nurses are already doing this during their rst two years in pracfice for the reasons stated  
above.  
2. R 338.7004 / R 338.10602 (b)  
Thank you for proposing allowing the recently required 2 hours of implicit bias training per licensing cycle to  
count toward 25 contact hour relicensure requirements, similar to pain. This is appreciated and makes a lot of  
sense. This will result in less confusion as well. Many organizafions have been offering contact hours for implicit  
bias training that nurses technically can’t use toward confinuing educafion requirements, because it was  
required to be above and beyond the 25 hours.  
3. R 338.10602 (i)  
1
Please consider maintaining the 120 hours of precepfing for 5 contact hours provision as acceptable confinuing  
educafion rather than changing it to 120 hours of precepfing for 1 contact hour. This provision has been helpful  
in recruifing and rewarding much-needed preceptors for new nurses as well as students. There is great demand  
for willing, qualied nursing preceptors in our healthcare organizafions to mentor and train new nurses. Many  
organizafions are not able to pay preceptors a premium to serve in this role, which is demanding and necessary  
to ensure a supply of highly qualied nurses successfully enter the workforce and transifion into  
pracfice. Allowing nurses to precept in a 1:1 relafionship to claim 5 hours of confinuing educafion credit for 120  
hours of precepfing provides some recognifion of the value of this role. Changing this from 5 hours to 1 hour  
per 120 hours of precepfing is a take-away and hardly makes it worth using this toward confinuing educafion,  
essenfially devaluing the contribufions of preceptors. 120 hours of a preceptor relafionship is preꢀy typical of  
working with 1-2 students per semester.  
When this rule was added a few years ago during my tenure as the MIBON Chair and Rules Commiꢀee Chair, it  
was based loosely on the Kentucky Board of Nursing’s confinuing educafion requirements (even used some of  
the KY language verbafim in wrifing the rule). In Kentucky, nurses must complete 14 confinuing educafion hours  
annually, and are allowed to use 120 hours of precepfing to safisfy this requirement for the full 14 hours each  
year.  
I would urge you to either maintain the status quo and clarify that 120 hours of precepfing is worth 5 contact  
hours per cycle if there is confusion on this point, or even consider increasing this for a total of 10 or even 15  
hours per licensing cycle (which is sfill significantly less than KY=28 hrs/2 yrs). Many of our preceptors are  
precepfing constantly throughout the year, and would benet from this, as well as encourage more nurses to  
precept. Preceptors working with students or new employees are much needed, work hard, and must stay up to  
date on best pracfices for their department or specialty area to be able to mentor and teach  
others. Maintaining this level of experfise requires ongoing educafion and familiarity with best pracfices to be  
able to effecfively serve in this role and properly train and mentor other nurses and students. Preceptors are  
oꢁen our highest performing and most professionally developed nurses. They are essenfial to maintaining and  
expanding the pipeline of qualified nurses needed to combat the nursing shortage.  
Kentucky Board of Nursing references:  
hꢀps://kbn.ky.gov/educafion/Pages/Confinuing-Educafion-Competency.aspx  
hꢀps://kbn.ky.gov/KBN%20Documents/ce-preceptor-vericafion-form.pdf  
4. Similar to preceptors, there is a significant nursing faculty shortage. I would encourage you to consider allowing  
nursing clinical instructors that are directly supervising and training nursing students in clinical seꢂngs to claim  
some of their fime spent teaching toward their 25 contact hour relicensure requirement in a future rule set  
revision. Similar arguments could be made regarding the level of clinical experfise needed by instructors to  
maintain competency in teaching nursing students in the clinical seꢂng.  
Thank you for your considerafion of my comments and suggesfions, and for your service in protecfion of the public.  
Joshua Meringa, MPA, MHA, MBA, BSN, RN, NPD-BC  
Nurse Educator & Academic Liaison  
Nursing Practice & Development  
Corewell Health West  
616.391.1528 Direct  
616.301.4663 Cell  
2
corewellhealth.org  
100 Michigan St NE | MC 018  
Grand Rapids, MI 49503  
As a nursing professional development practitioner, I facilitate the development of nurses and allied health personnel from novice to expert. I achieve  
this by being a learning facilitator, change agent, leader, mentor, champion of scientific inquiry and partner for practice transitions.  
3
Przybylo, Kerry (LARA)  
From:  
Sent:  
To:  
BPL-BoardSupport  
Monday, October 16, 2023 7:02 AM  
Shaltry, Jennifer (LARA); Przybylo, Kerry (LARA)  
FW: A Few comments on CEU Changes  
Subject:  
From: Savalle, Jacqueline <jacqueline.savalle@corewellhealth.org>  
Sent: Friday, October 13, 2023 9:57 AM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: A Few comments on CEU Changes  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Hello Michigan Board of Nursing,  
It has come to my attention of discourse surrounding some changes to the CEU requirements for Michigan RN licensees.  
I would like to offer a few comments as you deliberate these decisions.  
I greatly support the 2 contact hours of implicit bias training to be included in the 25 continuing education requirements  
for each licensing cycle. This specific training is very important but it feels untruthful saying “you need 25 hours for  
continuing education PLUS two more of implicit bias training” While the pain management requirement falls under the  
25 hours.  
I would also like to express NOT supporting cutting 120 hours of precepting from 5 CEUs to 1 CEU. Precepting a new  
employee requires a wealth of knowledge and experience, as well as interprofessional collaboration skills. While I think  
5 is reasonable for that amount of time precepting, 1 CEU feels almost insulting. Can you imagine doing something like  
this for 120 hours and at the end being given a participation sticker? 5 CEUs is an appropriate amount of  
“compensation” for the intense amount of work it requires to be a preceptor. It is not a secret the nursing profession is  
drastically understaffed, and we are losing many senior RNs who are able to help us train, this is one of the ways we can  
show our support to our fellow colleagues.  
I appreciate your work and time in keeping our profession strong in the state of Michigan! And appreciate you listening  
to comments on this matter  
Best,  
Jacqueline Savalle MS, RN, CMSRN  
She/Her/Hers  
Adult Medical Surgical Nurse Educator  
Nursing Practice and Development  
248.756.6970-Cell  
corewellhealth.org  
1
1840 Wealthy St SE  
Grand Rapids, MI 49506  
As a nursing professional development practitioner, I facilitate the development of nurses and allied health  
personnel from novice to expert. I achieve this by being a learning facilitator, change agent, leader, mentor,  
champion of scientific inquiry and partner for practice transitions.  
2
Przybylo, Kerry (LARA)  
From:  
Sent:  
BPL-BoardSupport  
Tuesday, September 26, 2023 11:25 AM  
To:  
Przybylo, Kerry (LARA); Shaltry, Jennifer (LARA)  
Subject:  
Attachments:  
FW: [MSONfaculty] Fw: Open Comment Period for Nursing Administrative Rules Draft  
2022-36 LR - Strike-Bold (5-9-23) - Returned to BPL for corrections - Nursing -  
9-6-23.doc; Notice of Public Hearing for Nursing and Pharm CS 10.16.2023.pdf  
From: Jaime Sinutko <sinutkjm@udmercy.edu>  
Sent: Tuesday, September 26, 2023 9:52 AM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Subject: Fw: [MSONfaculty] Fw: Open Comment Period for Nursing Administrative Rules Draft  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Dear MI BON,  
Page 24 on the strike/bold Admin Rules attached is R 338.10303 Initial Program Approval Procedure.  
D) Impact of programs within 50 miles- this needs clarity if the Education Committee is requiring proof of  
email surveys to specific people (i.e. Nursing Director).  
(ix) Plans to recruit faculty needs clarification if the Educational Committee is requiring something more  
detailed or specific- what are they looking for?  
(xi) Student Policies and Student Support: needs clarification if the Educational Committee is requiring nursing  
student handbooks than that needs to be stated.  
Thank you for the opportunity to give feedback,  
Jaime  
Jaime Sinutko, PhD, MSN, RHIA, RN  
Assistant Professor  
College of Health Professions  
Offices: Macomb Community College  
University Center & West Wing A248  
McAuley School of Nursing  
University of Detroit Mercy  
4001 W. McNichols Road  
Detroit, MI 48221-3038  
cell: 248-561-7596  
office: 313-993-1573  
From: MSONfaculty <msonfaculty-bounces@listserver.udmercy.edu> on behalf of Janet Baiardi  
Sent: Tuesday, September 26, 2023 8:37 AM  
1
Subject: [MSONfaculty] Fw: Open Comment Period for Nursing Administrative Rules Draft  
Sharing this information regarding the notice of the public hearing and comments for rule changes.  
Sincerely,  
Janet M. Baiardi  
Janet M. Baiardi, PhD, FNP-BC  
Interim Dean & Professor  
College of Health Professions and McAuley School of Nursing  
University of Detroit Mercy  
313-993-2443  
From: Przybylo, Kerry (LARA) <PrzybyloK@michigan.gov>  
Sent: Tuesday, September 26, 2023 8:25 AM  
To: Adejoke Ayoola <adejoke.ayoola@calvin.edu>; Alisha Williams <awilliams@dbidownriver.edu>; Amy Polzin  
<amy.polzin@kirtland.edu>; Andrea Shaw <shawa511@macomb.edu>; Anne Loehnis <Aloehnis@abcott.edu>; Ayana  
Redding <ayanaredding@yahoo.com>; Barbara Harrison <harrisonb@andrews.edu>; Barbara Wieszciecinski  
Chris PAtterson <chris.patterson@muskegoncc.edu>; Christopher Coleman <clcoleman@oakland.edu>; Cynthia  
McCurren <mccurrec@umich.edu>; Daisy McQuiston <daisymcquiston@delta.edu>; Dana Tschannen  
<djvs@med.umich.edu>; Debbie Bosworth <dbosworth3@davenport.edu>; Debi Vendittelli  
<dvenditt@schoolcraft.edu>; Deborah Dunn <ddunn@madonna.edu>; Denise Gardner  
<gardner@lakemichigancollege.edu>; Diane Ames <Diane.Ames@cuw.edu>; Elizabeth Roe <eroe@svsu.edu>; Emily Ellis  
Janice Cecil <jcecil@madonna.edu>; Jeannette Pollatz <jpolla08@baker.edu>; Jennifer Avery <javery10@emich.edu>;  
Jennifer Otmanowski <jotman01@baker.edu>; Joanne Yastik <jyastik@sienaheights.edu>; John Collins  
<jcollins2@rochesteru.edu>; Joyce Russell <jrusse1@wcccd.edu>; Julie Bullinger-Ballow <bullingJuliem@jccmi.edu>;  
Katherine Menard <kmenard@nmu.edu>; Kathleen Poindexter <poindex9@msu.edu>; Kathy Berchem  
<kberchem@lssu.edu>; Kelli Leask <leaskk@alpenacc.edu>; Kelly Martin <kmarti05@baker.edu>; Kim Garza  
<kgarza6@davenport.edu>; Kim Lindquist <klindquist@monroeccc.edu>; Laurie Clabo  
<laurie.lauzon.clabo@wayne.edu>; Leigh Small <lsmall@msu.edu>; Lisa Singleterry <lisa.singleterry@wmich.edu>; Lori  
Dewey <lori.dewey@baker.edu>; Lori Glenn <glennla@udmercy.edu>; Lori Orr <lorr@kvcc.edu>; Lori Sullivan  
<lori.sullivan@finlandia.edu>; Lukesha Ledbetter-Lee <Lledbetter-Lee@Dorsey.Edu>; Marilyn Lawrence  
Melissa Kennedy <mkennedy03@swmich.edu>; Melodee Babcock <babcockmm@alma.edu>; Michelle Hagstrom  
2
<mhagstrom@davenport.edu>; Michelle Richter, MSN, RN <mrichter@grcc.edu>; Mindy Rice <Mindy.Rice@arbor.edu>;  
Misty Emmons <misty.emmons@cornerstone.edu>; Nancy Garland <nancy.garland@miqht.org>; Nicole Rowe, MSN, RN  
<NicoleR@gogebic.edu>; Patricia Thomas <thomasp1@gvsu.edu>; Phyllis Eaton <peaton@chamberlain.edu>; Renee  
Gilbert <renee.gilbert@baker.edu>; Robbyn Smith <rsmith@dorsey.edu>; Rochelle Boes <rboes@westshore.edu>;  
Roxanne Roth <rlroth@madonna.edu>; Sandra Croasdell <croasdes@baycollege.edu>; Sarah Birch  
<sbirch226@glenoaks.edu>; Selena Neal <sneal@dorsey.edu>; Shannon French <sfrench02@baker.edu>; Sheila  
Douglas-Collins <scollin1@wcccd.edu>; Sonya Sevilla <ssevilla@dorsey.edu>; Stephanie Soulia  
<stephanie.soulia@mcc.edu>; Suzanne Keep <keepsm@udmercy.edu>; Tamella Livengood <Tlivengood@nmc.edu>; Teri  
Logghe <logghet@lcc.edu>; Terrie Franks <tfranks@hondros.edu>; Theresa Bucy <tbucy@wccnet.edu>; Therese  
Jamison <mjamison@ltu.edu>; Tracy Alberta <talberta2@davenport.edu>; Tracy Dunsmore <tldunsmore@sc4.edu>;  
Tracy Zamarron <Tracy.Zamarron@montcalm.edu>; Trina Moore <tmmoore13@hfcc.edu>; Twanda Gillespie  
Subject: Open Comment Period for Nursing Administrative Rules Draft  
Warning: This email originated from outside of the University. Do not click links or open attachments unless you  
recognize the sender and know the content is safe.  
Dear Directors of Nursing:  
The public hearing to receive comment on the nursing administrative rules is set for October 16, 2023.  
Please review the revised changes. If you wish to make a comment you may do so in one of two ways: In person or in  
writing by sending your comment to BPL-BoardSupport@michigan.gov by 5:00 p.m. on October 16, 2023.  
The rules committee has worked hard to provide better clarity. However, if you have suggested changes, please provide  
the proposed language for adoption.  
Warm regards,  
Kerry  
Kerry Ryan Przybylo, JD  
Manager, Boards and Committees  
Bureau of Professional Licensing  
Department of Licensing and Regulatory Affairs  
611 W. Ottawa Street  
Lansing, Michigan 48909  
(517) 342-4971 (cell)  
3
Przybylo, Kerry (LARA)  
From:  
Sent:  
To:  
Subject:  
Attachments:  
BPL-BoardSupport  
Monday, October 2, 2023 12:08 PM  
Shaltry, Jennifer (LARA); Przybylo, Kerry (LARA)  
FW: Comments for October Nursing Public Hearing  
Comment for Public Hearing.docx  
From: Deborah S. Vendittelli <dvenditt@schoolcraft.edu>  
Sent: Monday, October 2, 2023 11:51 AM  
To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>  
Cc: Deborah S. Vendittelli <dvenditt@schoolcraft.edu>; Przybylo, Kerry (LARA) <PrzybyloK@michigan.gov>  
Subject: Comments for October Nursing Public Hearing  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Hello, please see the aꢀached for some comments related to the nursing rules.  
Thanks!  
Dr. Debi Vendittelli,DNP, RN, APRN-BC  
Associate Dean-Nursing  
Direct | 734-462-4456  
Nursing Department | 734-462-4401  
Nursing Fax | 734-462-4473  
18600 Haggerty Rd., Livonia, MI 48152-2696  
Schoolcraft.edu  
1
Dear BPL  
I have a comment about a few rules in this set.  
1) R 338.10105, R 338.10601, and R 338.10602 are inconsistent with regards to the required  
training to idenfify vicfims of human trafficking.  
R 338.10105 states that the training for idenfifying vicfims of human trafficking must be done by  
all those who are licensed or seeking licensure. This is a one-fime training requirement.  
R 338.10601 pertains to license renewals. It states that an applicant for license renewal shall  
complete a 1-fime training idenfifying vicfims of human trafficking as required in R 338.10105.  
R 338.10602 states that the training for idenfifying vicfims of human trafficking does not count  
toward the confinuing educafion requirements.  
My quesfion is why is the one-fime licensure training in R 338.10105 being required for each  
renewal thereaꢀer without any confinuing educafion credit? My suggesfion is to remove  
proposed subrule (3) from R 338.10601 to avoid confusion.  
2) R 338.10303 pertains to inifial program approval. Some claricafion is needed regarding the  
impact on all exisfing nursing educafion programs in a 50 mile-radius of the proposed program.  
It is my understanding that the board requires a survey to be sent to each program. However,  
the rule does not specically state this nor outline the required quesfions.  
Suggested language:  
(D) Impact on all exisfing nursing educafion programs in a 50-mile radius of the proposed  
program. A survey should be sent directly to the director of nursing for each program within  
the radius including, at least, all of the following quesfions:  
(1) What extent would this proposed program have on your nursing program?  
(2) What extent would this new program have on student clinical learning experiences in your  
nursing program?  
(3) To what extent would this new program have on faculty hiring in your nursing program.  
(4) Approximately how many qualified student applicants do you turn away from admission  
annually?  
(5) Do you plan to increase enrollment in your nursing program in the next 2 years?  
(6) Do you have any addifional comments?  
Addifionally, I suggest that the phrase “or leꢁers of commitment” be removed from subrule  
(b)(vii).  
3) R 338.10303b pertains to confinued program approval; self-study and nursing educafion  
program report requirements.  
Subrule 1(d): Should any of these outcomes be leveled?  
Subrule 3 pertains to the content of the nursing educafion program reports. This should be  
amended to include more useful informafion regarding the program. Suggested edits are below:  
(3) Aꢀer a program has been granted full approval under R 338.10303a, the sponsoring agency  
shall submit a nurse educafion program report to the board every 4 years for a non-accredited  
program or at the midpoint of the accreditafion cycle for nafionally accredited programs. The  
nursing educafion program report must include all the following informafion for all of the years  
since the last self-study report was approved by the board:  
(a) Admission, progression, and retenfion of students. Program informafion pertaining to total  
program length, required credits, and all required courses in the program’s plan of study.  
(b) Student achievement on the required licensure NCLEX exam. Analysis and acfion plans for  
program outcomes including program complefion rates, rst-fime NCLEX pass rates, and job  
placement rates.  
(c) Systemafic program evaluafion results and acfion plan, including but not limited to, student  
evaluafions, faculty reviews, NCLEX evaluafion results, and aꢁrifion rates. Nafional nursing  
accreditafion status (if accredited).  
(d) Program changes. Faculty qualicafions, assignments, and any faculty excepfions.  
(e) Faculty qualicafions, assignments, and any faculty excepfions. End of program student  
learning outcomes for each program opfion.  
(f) Leveled student learning outcomes or objecfives used to organize the curriculum.  
(4) R 338.10310a pertains to board acfion following an evaluafion.  
Subdivision (1)(a)(iv) needs claricafion of what is to be included in the NCLEX Improvement Plan.  
Suggested language: A method for the evaluafion of the changes and further acfion to be  
taken if program performance confinues to be out of compliance. The evaluafion method  
should include, but is not limited to, an evaluafion of student achievement of course learning  
outcomes and end of program student learning outcomes considering the changes.  
Sincerely,  
Debi Vendiꢁelli, DNP, RN, APRN-BC  
;