Rural community colleges are struggling with clinical placements in general and especially in specialty units.  We are land locked and what clinical placements we can find are struggling with low census, staffing issues, high turnover rates, inexperienced nurses, and poor learning environments for students.  We are also struggling with the continued problem of finding qualified clinical faculty as many schools across the state are.  With the known benefits of simulation and the ability to provide students with robust controlled learning opportunities, please reconsider the 50% cap on simulation hours.  Especially the piece that that states "if the courses are integrated, simulation shall not be used for more than 50% of the total hours in different clinical specialties and population groups across the life span".  As many of us rural colleges are desperately struggling to find specialty placements and it would be very helpful if we could supplement more than 50% of the hours with simulation in these specialty areas. 

Students can be given more learning opportunities and the ability to utilize critical thinking skills in a safe environment that they cannot do in a live patient situation.  It allows students to learn through making mistakes and interacting with peers through collaboration. 

Thanks for your time and consideration.