Controversial Proposals Phase II - Page 3

thank you so much for your interest and support! here is the official response from the north carolina association of community college presidents:

to: ms. linda blain

north carolina board of nursing



from: dr. gordon burns, president

north carolina association of community college presidents



re: concerns with draft education rules



the north carolina association of community college presidents represents all of the presidents of north carolina’s 58 community colleges. at our association’s meeting on january 28, the presidents of north carolina unanimously approved the responses on the attached feedback form concerning the draft education rules.



our community colleges, as is the board of nursing, are committed to the highest standards and quality of nursing education. we thank you for the opportunity to respond as we work together to serve the people of this great state in both rural and urban, low-wealth and prospering, and declining and growing communities in need of adequate access to healthcare.



gordon burns

president

wilkes community college

(336) 838-6112


north carolina board of nursing

draft education rules feedback form

section .0300 - approval of nursing programs


directions: your feedback is important. please place any comments about the rules under the corresponding section on the form below and send by email to linda blain, education secretary (lindab@ncbon.com). you may expand the space under each section to accommodate your comments. comments will be accepted until february 25, 2005.


this response is from the north carolina association of community college presidents representing all 58 community college presidents in north carolina. this document was approved unanimously by vote of the membership on january 28, 2005.


21 ncac 36.0120 definitions


the ncaccp has a concern with page 3, lines 5 – 18, which describe “program type.” within the definitions of “bsn” and “adn/diploma in registered nursing” the language identifies “adn/diploma” as a rn and does not recognize “bsn” as a rn. if the intent is to create a new status of bsn, which is a higher level than rn, then the language should clarify this point. if a “bsn” is a rn, then the draft language implies that registered nurses come in more than one level with differing scopes of practice.

21 ncac 36 .0302 establishment of a nursing program - initial approval


21 ncac 36 .0303 existing nursing program


the ncaccp has a concern with page 7, lines 38 – 40: “(a) all nursing programs under the authority of the board shall obtain program accreditation by a board approved nursing accreditation body by december 31, 2015. thereafter, the program must maintain national accreditation to continue board approval.”

the ncaccp suggests that national accreditation be voluntary for both associate degree nursing programs and practical nursing programs. there does not appear to be a correlation between national accreditation, the costs associated with accreditation, and the successful passing rates of accredited programs. the ncaccp believes community colleges and the state board of nursing should work together to provide quality programs preparing students to graduate and successfully pass the nclex. national accreditation does not necessarily accomplish this goal. it appears all bsn programs in north carolina are nationally accredited, while only a few community college programs are nationally accredited. the 2003 average passage rate for north carolina’s bsn programs was 87% while the average passage rate for community college adn programs was 91%. neither nclex passing rates nor employer satisfaction surveys in north carolina support the idea that national accreditation of nursing programs adds value to the program, the graduates, or the licensed nurse in the workplace. the ncaccp suggests that our limited resources would be better spent addressing retention of students than pursuing national accreditation.


21 ncac 36 .0309 process for closure of a program


21 ncac 36 .0317 administration


the ncaccp has a concern with page 11, lines 34 – 39, which describe qualifications for program directors.

the ncaccp suggests that the director of a practical nurse program have a baccalaureate degree in nursing and a minimum of two calendar year’s prior full-time employment or the equivalent in clinical nursing practice as a registered nurse.

the ncaccp suggests that the director of an associate degree nursing program have a minimum of a bsn and a master’s degree in nursing, or a master’s degree and at least 18 graduate semester hours in nursing.



21 ncac 36 .0318 faculty


the ncaccp has a concern with page 13, lines 11 – 19, which describe proposed changes in faculty qualifications.

the ncaccp is concerned that the rural areas of north carolina have a small number of master’s prepared faculty members and have difficulty recruiting master’s prepared nurses. this rule change will impact negatively on the very areas of north carolina having the greatest need for nursing programs to meet community needs. it is very difficult to find part-time faculty members with a bsn and nearly impossible to find part-time faculty with a master’s degree.

the ncaccp suggests that the existing faculty qualifications in title 21 north carolina administrative code, chapter 36, section .0318 continue to be the minimum faculty qualifications and that none of the proposed changes be enacted.



21 ncac 36 .0321 curriculum


the ncaccp has a concern with page 17, lines 14 – 19, which describe clinical hours within a set time frame.

the ncaccp is concerned that this rule may place a burden on clinical facilities that serve as resources for numerous nursing programs, especially if clinical facility staff is utilized as preceptors.

the ncaccp suggests that the timing of the hours not be mandated and that the scheduling of clinical experiences be flexible to accommodate facility and program needs.

the ncaccp has a concern with page 18, lines 33 – 35, which describe average student retention rates.

the ncaccp suggests that the board delete this rule related to retention. community college students do not fit the traditional 18 to 21 year-old college student model. our students have many adult and family responsibilities that influence their ability to successfully complete a nursing program. a nursing program cannot control many of these variables, especially issues of a personal and financial nature. this rule might penalize programs in poor and underserved areas where nursing shortages are greatest.


21 ncac 36 .0322 facilities

21 ncac 36 .0323 records and reports

21 ncac 36.0324



thank you for sharing your comments.

Especially since the entire board of The North Carolina Association of Community College Presidents has UNANIMOUSLY come against the most damaging parts of these proposals. I don't think this has ever happened in the whole history of the NC Community College system.