The Virginia Hospital & Healthcare Association appreciates the opportunity to comment on the Board of Nursing’s proposed amendments to regulations governing criteria for approval of nursing education programs (18VAC90-20 et seq.).  Generally, we believe that the proposed changes significantly improve the regulations.

The only suggestion we offer for revision of the proposal is related to 18VAC90-20-121. Curriculum for direct client care.  In Subsection D 1 of that section, we suggest increasing the proposed limit on direct client contact hours that may be simulated client care hours from the proposed 20% to 25% if simulation includes computerized patient simulation and advance technologies such as patient actors.  Given the sophistication of the computerized “patients” and patient scenarios available, 20% seems unnecessarily restrictive.