Public Comment — 18VAC90-27 / Action 6759

I object to the use of the fast-track process for Action 6759 and request that these accountability and procedural-safeguard questions be considered through the normal regulatory process before the existing level of review is removed.

I previously submitted written public comment to the Virginia State Board for Community Colleges on May 21, 2026, raising concerns regarding transparency, documentation integrity, access to audit information, independent review, and procedural safeguards within nursing education.

I am submitting this comment because Action 6759 raises a closely related question about accountability and review within Virginia’s nursing education oversight structure.

The Board’s regulatory background document states that nursing education informal conference recommendations currently go before the Board of Nursing or a panel for review and action. The proposed amendment would remove that additional review step. For example, under the proposed change to 18VAC90-27-130, if an informal conference denies approval, the decision would be reflected in a Board order and “no further action by the board is required.”

The same structural change would apply to decisions involving denial of full program approval and continuation or withdrawal of full approval.

I understand the Board’s stated goal of reducing unnecessary delays and creating consistency among informal conference procedures. However, efficiency should be balanced with meaningful safeguards, particularly when decisions involve the approval or continued operation of nursing education programs.

The agency states that this proposal creates a “less stringent level of review,” while also concluding that there are “no disadvantages to the public.” I respectfully ask the Board to explain how that conclusion was reached and what safeguards will replace or preserve the accountability currently provided by Board-level review.

Specifically:

Who independently reviews an informal conference decision after the additional Board review is removed?

What appeal or reconsideration rights remain available to a nursing education program?

Will the complete administrative record, evidence considered, findings, and written reasoning supporting the decision be preserved and accessible for subsequent review?

What safeguards address potential conflicts of interest, inconsistent application of standards, or material factual or record discrepancies discovered after an IFC decision?

If significant new evidence or evidence of procedural error emerges after the decision, what mechanism exists to obtain meaningful review?

These questions reflect the same concern I raised in my May public comment: when an institution or regulatory body makes a decision affecting nursing education, there should be a clear and transparent answer to who reviews the reviewer.

Nursing students are trained that documentation, verification, escalation, and independent checks are fundamental to patient safety. Those principles should also be visible in the systems governing nursing education.

For that reason, I respectfully ask the Board to consider whether eliminating an existing level of review without clearly defining the remaining appeal, record-integrity, conflict-of-interest, and independent-review safeguards is appropriate for fast-track rulemaking.

I therefore object to the use of the fast-track process for Action 6759 and request that these accountability questions receive consideration through the normal regulatory process before the existing level of review is removed.

My purpose is not to oppose efficient regulation. It is to ensure that efficiency does not come at the expense of transparency, procedural safeguards, documentation integrity, and public trust in nursing education oversight.

Thank you for the opportunity to comment.