The members of the Virginia Association of Colleges of Nursing (VACN) request that the Virginia Board of Nursing clarify the Regulations for Nursing Education Programs, Section 18VAC90-27-110 to promote best practices for public health nursing clinical education.
The recently rescinded Guidance Document #90-21 (February 2017), in particular sections 2 and 3 of the Exceptions to Direct, On-Site Supervision in Nursing Education Programs (heretofore called “Exceptions”) aligned with the National Academies of Sciences, Engineering, and Medicine Future of Nursing 2020-2030: Charting a Path to Achieve Health Equity (NASEM, 2020) and the World Health Organization Framework for Community Health Nursing Education (WHO, 2010). Without these exceptions, the regulations overly restrict education in a greatly needed area of healthcare and will discourage students from pursuing careers in public health nursing.
The NASEM Future of Nursing report highlights the nursing role in promoting health equity through recognition and action against systemic inequities and structural racism in society that impact public health. To achieve this, nursing education must provide students with a broad range of substantive experiences such as in schools, homes, workplaces, homeless shelters, and public health clinics. Further, students must engage in an equally broad range of exposures to community health systems such as identification of community health resources, assessment of community conditions and risks to health, design and implementation of public health interventions, and evaluation of local policies and laws on community health (WHO, 2010). Congruently, the 2021 AACN Essentials emphasize diversity, equity, and inclusion and are centered on four spheres of care, one of which is disease prevention and health promotion (AACN, 2021). The Essentials state that “the workforce of the future needs to attract and retain registered nurses who choose to practice in diverse settings, including community settings to sustain the nation’s health (AACN, 2021, p. 8). Rethinking the role of nurses in public health and promoting primary care as a career choice for new graduates will require creativity, community engagement, and a plan for broad, interesting, and impactful experiences for students.
Currently, BON regulation 18VAC90-27-110: Clinical practice of students restricts best (and needed) practices for public health nursing education in two ways. First, as defined in 18VAC90-27-10 (p.4), the current definition of direct client care is incongruent with the American Nurse Association Scope and Standards of Practice for Public Health Nursing (2013). Systematic needs assessments are in line with the Scope and Standards of public health nursing practice, are promoted by the Council of Public Health Nursing Organizations (CPHNO) as a core competency and are important clinical learning experiences to develop the skillset as a critical first step to identify health disparities and promote health equity. Realignment of the BON regulations with standards of practice for public health nursing is urgently needed.
Second, section F.1 states “The faculty member shall be on site in the clinical setting solely to supervise students.” This generates confusion for community/public health nursing where “clinical settings” include public school systems, public housing developments, and workplaces. Faculty members are “on site” in that they are present within the clinical setting but, given that students are distributed in different areas of the clinical setting, faculty members are not directly supervising the actions of all students during the clinical day. Clarification of these issues as they apply to community/public health nursing education is necessary so that exposures to a broad array of diverse and substantive community health issues are possible and standards of practice can be achieved.
We urge the BON to support public health nursing education by providing freedom to teach students in a way that engages their intellect and desire to address health equity. This is a very exciting time for public health nursing—long awaited and greatly needed. Thank you for considering clarification of the regulations so that they promote clinical exposures for students that highlight the full scope of public health nursing practice now and well into the future.
AACN Essentials (2021). The Essentials: Core Competencies for Professional Nursing Education. Retrieved April 15, 2022 from https://www.aacnnursing.org/Portals/42/AcademicNursing/pdf/Essentials-2021.pdf.
American Nurses Association (2013). Public Health Nursing: Scope and Standards of Practice, 2nd ed. Silver Spring, Maryland. https://www.nursingworld.org/nurses-books/public-health-nursing--scope--standards-of-practice-2nd-edition/.
National Academies of Sciences, Engineering, and Medicine 2021. The Future of
Nursing 2020-2030: Charting a Path to Achieve Health Equity. Washington, DC:
The National Academies Press. https://doi.org/10.17226/25982.
World Health Organization (2010). A framework for community health nursing education. Retrieved November 10, 2022. https://apps.who.int/iris/bitstream/handle/10665/204726/B4816.pdf