October 30, 2007

Sharon J. Tanner, EdD, RN
Executive Director, NLNAC
61 Broadway, 33rd Floor
New York, NY 10006

RE: Draft 2 of the 2008 NLNAC Standards and Criteria—Proposed Guideline Changes for Diploma Programs

Dear Ms. Tanner:

The Hospital & Healthsystem Association of Pennsylvania (HAP), on behalf of its members, more than 250 acute and specialty hospitals and health systems and their related hospital-based nursing education programs, appreciates the opportunity to provide comments on the proposed guideline changes for diploma programs as it relates to the National League for Nursing Accrediting Commission’s (NLNAC) Standards and Criteria.

HAP appreciates the Committee on Accreditation Standards and Criteria’s efforts to develop the most comprehensive standards and criteria for nursing education programs, but would recommend that the Committee consider the following recommendations as they relate to diploma programs:

Standard I—Mission and Administrative Capacity

• §1.3—Communities of interest have input into program processes and decision-making
  
  HAP recommends providing examples of what is meant by “Communities of Interest” to provide more clear direction on who would be permitted to provide input into diploma program processes and decision-making while not limiting individual school interpretation.
  
• §1.5 and §1.6—Administration of the Nursing Education Program
  
  HAP recommends that these two sections be combined to outline that the nurse administrator has the qualifications, authority and responsibility to administer the nursing education program.
  
• §1.7—Program Budget
  
  HAP recommends that all discussion with regard to the aspects of the program budget and its development should be outlined only in one section of the standards and criteria document to alleviate any unnecessary repetition. HAP suggests that §1.7 be removed and the language with regard to the development of the budget should be incorporated in §5.1 of the standards and criteria.

Standard II—Faculty and Staff

• §2.6—Non-nurse faculty
  
  HAP respectfully submits that the majority of Pennsylvania’s diploma programs do not have non-nurse faculty. As most of the diploma programs are affiliated with a local college or university for their pre-requisite and supportive courses, HAP recommends that §2.6 be removed.
  
• §2.9 Staff performance
  
  This section requires that staff performance be regularly reviewed; however, it does not sufficiently identify what it means by “staff.” HAP questions whether “staff” means the secretaries and library staff of the nursing education program, or does “staff” include supportive staff such as counselors or employee health staff. As diploma program nurse administrators do not have input into the performance appraisals of employee assistance counselors, employee health staff or others in departments different from the school, HAP recommends that the term “staff” be clearly defined in this section as it relates to the nursing education program.

Standard VI—Outcomes

• §6.3—Evaluation findings
  
  This section references that evaluation findings and outcomes are to be shared with “communities of interest.” As stated previously, in an effort to promote clarity, HAP recommends providing examples of what is meant by “Communities of Interest.”

Criteria for Distance Education

• Each standard outlines the provision of criteria for those nursing education programs engaged in distance education. As schools who are writing self-studies in preparation for reaccreditation site visits are limited to the number of pages that can be submitted and in an effort to alleviate the unnecessary duplication of comments, HAP recommends that a separate standard be created to address the necessary criteria for those entities that have distance education capability.

Again, HAP appreciates the opportunity to provide comments on the proposed guideline changes for diploma programs. If you have any questions about HAP’s comments, please feel free to contact me at (717) 561-5308 or by email at lgleighton@haponline.org or Mary Marshall at (717) 561-5312 or by email at mmarshall@haponline.org.

Sincerely,

LYNN G. LEIGHTON
Vice President, Professional & Clinical Services