Virginia Regulatory Town Hall
Department of Health Professions
Board of Nursing
Regulations for Nurse Aide Education Programs [18 VAC 90 ‑ 26]
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1/31/22  2:52 pm
Commenter: JoAnna Collins

Support Petition 356

As an Instructor and Coordinator, I would like to offer my support for this petition. Nurse Aide (NA) programs have difficulty securing clinical sites and this request would remove some of the clinical site barriers for nurse aide students and programs. As many hospitals prefer CNAs as entry to practice in bedside care, this would also provide experience in these facilities. Hospitals have many opportunities for students to perform skills required by NA students. Some hospital units, such as Medical-Surgical, often have more opportunities for students to perform care than nursing homes such as catheter care, bedpan, bed bath, and Vital sign measurement- skills that are the most failed on the exam demonstrating the need for more practice opportunities. I don't agree that ALL units of a hospital would be appropriate for NA students, but this could be remedied by requiring the units have skilled care, adult patients.

Additionally, because Nurses (LPNs and RNs) approved to teach are required to have 12 hours of training before they are allowed to teach in a NA program, it is unnecessary for nurses, who are trained in all levels and stages of patient care, to have a nursing home experience requirement to teach. It is necessary for instructors to be experienced nurses, but the nursing home experience requirement is so restrictive that many well-qualified instructors are turned away from teaching. This leads to a shortage of well-qualified instructors.

Finally, it makes sense to allow clinical instructors to oversee a lower ratio of students while they are in the facility working. With concerns about the prevalence of infection and introducing non-essential personnel to at-risk clients such as the elderly, this would be a great compromise. In my opinion, Directors of Nursing should not oversee students as they have too many responsibilities to effectively monitor students, but Staff Development Coordinators/Educators and floor nurses are great options to oversee students working on their units.

Thank you for considering this petitioner's request. With the addition of requiring the hospital units have skilled care, adult patients, I fully support these changes.

CommentID: 119189