Dear DMAS Revision Committee,

It is with great passion that I support the comments already presented on this board, including statements from VASN, VCASE, and Heather Snyder & Amy Barnett (both colleagues from Chesterfield County Public Schools). As a special education nurse who works specifically with families and students who have IEPs and MULTIPLE physicians, I can assure you that it is quite complex to gather LHP s’ orders EVERY year before the start of school.  Treatments, medications and procedures change frequently during he course of the year, requiring new or updated orders each time. School environments are set up differently and staff patterns cannot be compared from one school to the next... only those who work directly with the students can provide input on the actual services needed in order for  them to access FAPE in the least restrictive environment. Licensed healthcare providers have no idea what resources our specific schools have available, nor do they understand the amount of time it takes to provide ADLs In the school environment. LHPs do not know which schools have fulltime RNs vs. clinic assistants manning clinics.  It is the role of the LHP to order medications, treatments, and procedures, as necessary.  They should include their NPI number in any such orders sent to school and be prepared to be called upon for clarification, if justified.

It is the registered school nurses’ role to apply the standards of practice for school nursing, as follows (NASN, 2017): Assessment, Diagnosis, Outcomes Identification, Planning, Implementation, and Evaluation. This includes collection of data (LHP orders), the survey of the environment and available resources, assessment of student information and physical assessment, Plan of Care creation, emergency action plan implementation, training of staff, providing care, documentation...

Registered Nurses do not need to have Plans of Care signed off by LHP.  Again, It is within a school nurses scope and standard of practice to read LHP orders and provide care accordingly. 

Please reconsider your current revisions and invite me to be in your next revision committee. 

Thank you for reading all of our comments. 

Angela Moore, MBA, BSN, RN, NCSN, CDDN