I believe the proposed regulation that the primary instructor while instructing students, should assume no other duties is desperately needed.  In many schools in Virginia, the instructor also doubles as the school nurse and therefore is pulled away from his/her classroom.  This will lead to students being unsupervised while the instructor is treating their patient, and to lost instructional time.  The loss of instructional time will now become a bigger issue as we are proposing adding additional hours needed to the program as a whole.  I believe it is of utmost importance to pass the proposed regulation that primary instructors may not have other duties assigned to them while they are instructing their students.

I recommend the 2 day required TTT/NA class be 10 hours over 2 days and the refresher class be 5 hours in one day.  (It is listed as 12 hr and 6 hr).   In my experience over the last 6 years, the content can be covered in this amount of time.  Keeping the class "user friendly" is important for those that commute an hour or two to fulfill this requirement. Thank You!

An increase in 20 hours is quite a substantial increase that we will need to pay faculty.  Tuition will need to increase in turn.  Unfortunately, I fear that we will need to close our program, the program costs and tuition are already unsustainable, for the school and the student. 

The refresher course should be hosted by the Board of Nursing in conjunction with the testing agency.  The VBON Nurse Aide training program courses I have attended in the past have been very beneficial.  I would attend annually if they were offered.

I agree with the comment from NOVA.  Adding 20 hours is a sticky wicket for community colleges, who charge by the credit.  It would increase tuition, increase the pay needed for faculty, and require increased time in the lab, for which we already compete with the PN and RN programs.

Any program that feels that their pass rate on the NNAAP is too low or that the students are not demonstrating competency in skills is free to increase the number of hours spent practicing in the lab, independent of a  directive from the Board of Nursing.   

If the impetus for increased 20 hours in skills training is truly based off of NNAAP results, perhaps the BON could also require a 20 hour mandatory Nurse Evaluator Training for Credentia; at the state level. The standards and inconsistancies amoungst Virginia evaluators is troubling ......you may see skills scores go up without increasing class hours.  

While I believe it is imperative for Instructional staff to have to have current relevant continuing education, I believe the current TTT offerings need to be re-evaluated. Training similar to state evaluators (skills performance) would be very helpful. I also suggest encouraging consistency among the state evaluators would improve outcomes. I have experienced good and bad evaluators (Good being fair, patient and understanding; bad being rude, demanding, not engaged in watching “evaluating”). 

Reviewed changes and all seem within reason.