BOARD OF VOCATIONAL NURSING NURSING AND PSYCHIATRIC ...€¦ · 2/22/2019 · Nursing Education...

T BOARD OF VOCATIONAL NURSING AND PSYCHIATRIC TECHNICIANS

Agenda Item #15.B.2

BUSINESS, CON SUMER SERVICES ANO I-IOUSING AGENCY • GAV1N Nev,,so,,..,,, GOVERNOR

DEPARTMENT OF CONSUMER AFFAIRS • BOARD OF VOCATIONAL NURSING AND PSYCHIATRIC TECHNICIANS 2535 Capitol Oaks Drive, Suite 205, Sacramento, CA 95833 P (916) 263-7800 I www.bvnpt.ca.gov

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Agenda Item #15.B.2

DATE January 18, 2019

TO Board Members

FROM Faye Silverman, RN, MSN/Ed., WOCN, PHN Nursing Education Consultant

SUBJECT Hacienda La Puente Adult Education Vocational Nursing Program Consideration of Placement on Provisional Approval (Director: Suzanne

Zemer, La Puente, Los Angeles County, Adult School)

STAFF SUMMARY: Hacienda La Puente Adult Education Vocational Nursing Program is presented to the Board for placement on provisional approval. On July 15, 2018, the assigned Nursing Education Consultant (NEC) at the Board of Vocational Nursing and Psychiatric Technicians (Board) received multiple complaints against the Hacienda La Puente Adult Education Vocational Nursing Program. On July 18, 2018, the Board sent a letter requesting documentation related to those complaints. Documentation of the complaints was submitted by August 1, 2018, to the NEC. After review of those documents, five violations were identified. On September 4, 2018, based on the identified five violations, the Executive Officer rescinded the program’s ongoing admissions to admit two full time classes of 30 students per calendar year to replace graduating classes, and required the program to admit no additional classes without prior approval by the Board. On September 5, 2018, the program was sent a notice of violations via certified mail. The program was required to submit documentation of correction of the five identified violations and submit a report by September 21, 2018, that substantiates the adequacy of program resources. The program submitted the required report on September 24, 2018, but it was incomplete. Additionally, on September 24, 2018, the assigned NEC at the Board received additional complaints against the Hacienda La Puente Adult Education Vocational Nursing Program. It was determined that Board staff would conduct an onsite inspection. The unannounced onsite inspection was conducted October 23 - 25, 2018. The original five violations had not been corrected at the time of inspection and sixteen additional violations were identified. A total of twenty-one violations were identified.

Agenda Item # 15. 8.2 Agenda Item #15.B.2

On October 29, 2018, the assigned NEC sent a certified letter to the program director listing the twenty-one violations. The letter requested submission of documentation to correct all twenty-one violations by December 1, 2018 The program is now presented to the Board in accordance with Section 2526.1(c) of the Vocational Nursing Rules and Regulations, which states:

“The Board may place any program on provisional approval when a program does not meet all requirements as set forth in this Chapter and in Section 2526…”

STAFF RECOMMENDATIONS: 1. Place the Hacienda La Puente Adult Education Vocational Nursing Program on

provisional approval for the two-year period beginning February 22, 2019; and issue a notice to the program to identify specific areas of non-compliance and requirements for correction as referenced in Section 2526.1 of the Vocational Nursing Rules and Regulations.

2. Require the program to correct existing twenty-one violations identified during the onsite inspection and submit documentation of corrections of all violations no later than May 1, 2019.

3. Require the program to admit no additional classes without prior approval by the

Board.

4. Require the program to submit a report to the Board in seven months, no later than September 2, 2019, and twenty-one months, no later than November 1, 2020. The report must include a comprehensive analysis of the program, timeline for implementation, and the effect of employed interventions. The following elements must be addressed in the analysis.

a. Admission and Screening Criteria. b. Terminal Objectives. c. Evaluation of the current curriculum to include:

1. Program Objectives 2. Instructional Plan 3. Theory and Clinical Objectives for each course 4. Lesson Plans for each course 5. Evaluation of correlation of theory and clinical content 6. Textbooks

d. Evaluation of the following student policies: 1. Attendance Policy 2. Remediation Policy 3. Evaluation of Student Achievement

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Agenda Item #15.8.2 Agenda Item #15.B.2

4. Credit Granting e. Evaluation of available clinical facilities approvals to determine adequacy in

number and variety of patients to accommodate current and projected students and to allow opportunity for the students to meet clinical objectives.

f. Evaluation of theory and clinical faculty. g. Evaluation of theory presentations. h. Evaluation of student achievement.

5. Require the program to provide no less than one (1) instructor for every ten (10)

students in clinical experiences.

6. Require the program to comply with all approval standards in Article 4 of the Vocational Nursing Practice Act, commencing at Business and Professionals Code, section 2880, and Article 5 of the Board’s Regulations, commencing at California Code of Regulations, Title 16, section 2526.

7. Require the program to demonstrate incremental progress in correcting the

violations. If the program fails to satisfactorily demonstrate incremental progress, the full Board may revoke the program’s approval.

8. Place the program on the Board’s February 2021 agenda for reconsideration of

provisional approval.

History of Prior Board Actions

(See Attachment A, History of Prior Board Actions) Enrollment Approval by the Board is required prior to admission of each class. Hacienda La Puente Adult Education Vocational Nursing Program offers a full-time program of instruction which is 48 weeks in length. The following table represents current student enrollment based on current class starts and completions. The table indicates a maximum enrollment of 47 students during the period January 2018 through December 2018.

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ENROLLMENT DATA

CLASS DATES #Students #Students Total

Current or Admitted Enrolled Start Complete Completed

1/8/18 24 22 22

(*12/20/18)

7/2/18 31 25 22 + 25 = 47

(*6/21/19)

12/20/18 (Class of -22 47 – 22 = 25

1/8/18)

* Indicates projected completion date.

Licensure Examination Statistics The following statistics, furnished by Pearson Vue published by the National Council of State Boards of Nursing as “Jurisdictional Summary of All First-Time Candidates Educated in Member Board Jurisdiction,” for the period October 2016 through September 2018, specify the pass percentage rates for graduates of the Hacienda La Puente Adult Education Vocational Nursing Program on the National Council Licensure Examination

for Practical/Vocational Nurses (NCLEX-PN)

Hacienda La Puente Adult Education NCLEX-PN® Licensure Examination Data

Quarterly Statistics Annual Statistics*

# # % State Program State Variance Quarter Candidates Passed Passed Average Average Average Annual From State

Quarterly Annual Pass Rate Average Pass Rate Pass Rate [CCR §2530(l)] Annual

Pass Rate

Oct – Dec 2016 7 4 57% 70% 79% 74% +5

Jan – Mar 2017 6 3 50% 72% 73% 73% 0

Apr – Jun 2017 13 12 92% 68% 75% 74% +1

Jul – Sep 2017 13 11 86% 74% 77% 71% +6

Oct – Dec 2017 4 4 75% 69% 83% 71% +12

Jan – Mar 2018 13 13 100% 81% 93% 73% +20

Apr – Jun 2018 5 3 60% 79% 89% 76% +13

Jul – Sep 2018 3 3 100% 77% 92% 76% +16 *The Annual Pass Rate changes every quarter. It is calculated by dividing the number of candidates who passed during the current and previous three quarters by the number of candidates who tested during the same period. If no data is available for the relevant period, the statistic is carried over from the last quarter for which data is available.

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Based on the most current data available (July – September 2018), the program’s average annual pass rate is 92%. The California average annual pass rate for graduates from accredited vocational nursing programs who took the NCLEX-PN® for the first time is 76%. The average annual pass rate for the Hacienda La Puente Adult Education Vocational Nursing Program is sixteen percentage points above the state average annual pass rate. Faculty and Facilities Section 2534 (d) of the Vocational Nursing Rules and Regulations states:

“For supervision of clinical experience, there shall be a maximum of 15 students for each instructor.”

The current number of Board-approved faculty totals three, including the program director. The director has 80 percent administrative duties and 20 percent teaching duties. Of the total faculty, one instructor is part time and one is full time. Both instructors and the program director are designated to teach clinical. Based upon a maximum enrollment of 47 students, four instructors are required for clinical supervision. The utilization of faculty at clinical facilities is such that clinical instruction is not covered adequately. Section 2534 (b) of the Vocational Nursing Rules and Regulations states:

“Schools shall have clinical facilities adequate as to number, type, and variety of patients treated, to provide clinical experience for all students in the areas specified by Section 2533. There must be available for student assignment, an adequate daily census of patients to afford a variety of clinical experiences consistent with competency-based objectives and theory being taught.”

Submitted documentation indicates that the program does not have sufficient clinical facilities to afford the number, type and variety of patients that will provide clinical experience consistent with Board-approved competency-based objectives and theory being taught for current and proposed students. Other Considerations: On July 15, 2018, the assigned Nursing Education Consultant (NEC) received multiple complaints against the Hacienda La Puente Adult Education Vocational Nursing Program. On July 16, 2018, there were follow-up complaints from several students via email. On July 18, 2018, the Board sent a letter to the program director requesting the director’s response related to those complaints. The director’s response to the complaints was to be submitted to the Board by August 1, 2018. During review of those documents, the following five violations were identified:

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Section 2526 (a) (7) of the Vocational Nursing Rules and Regulations states:

“The institution shall apply to the Board for accreditation. Written documentation shall be prepared by the director and shall include: …(7) Instructional plan

Violation # 1: The program failed to present instruction consistent with the approved

instructional plan related to correlation between theory and clinical content. On August 1, 2018, the program director informed the NEC that the cohort admitted in June 2017 with a scheduled graduation in June 2018 had not finished its clinical instruction at the time of the scheduled graduation. The students in that cohort continued with supervised clinical experience after graduation to compete clinical hours. According to the approved instructional plan, the curriculum consists of 48 weeks of theory and clinical instruction. The theory and clinical instruction were to run congruently. The program director confirmed students were receiving academic instruction after graduating from the program in June 2018.

Status: This violation has not been corrected.

Section 2526 (a) (8) of the Vocational Nursing Rules and Regulations states:

“The institution shall apply to the Board for accreditation. Written documentation shall be prepared by the director and shall include: …(8) Evaluation methodology for curriculum

Violation # 2: The program currently has a Board-approved policy for evaluation of the

curriculum. The program failed to follow that policy.

Hacienda La Puente Adult Education, Vocational Nursing Program’s policy related to curriculum evaluation includes the following items:

“All students will be asked to evaluate instructors, clinical facilities and clinical staff after each term and overall program prior to graduation and the director review of all student evaluations.”

The program director was unable to provide documentation of student evaluations of instructors, clinical facilities, or clinical staff after each term and overall program.

Status: This violation has not been corrected.

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Section 2530(i) of the Vocational Nursing Rules and Regulations states:

“The school shall evaluate student performance to determine the need for remediation or removal from the program.”

Violation # 3: The program has a Board-approved remediation policy. Documents submitted indicate that the cohort that began in June 2017, started with 21 students and ended with 18 students. The cohort that began in June 2018, started with 17 students and currently has 10 students. The program director was unable to provide written documentation of remediation to demonstrate the policy was being used for these ten students. No evaluation of student progress was identified or documented.

Status: This violation is not corrected.

Section 2533(a)(b)(c) of the Vocational Nursing Rules and Regulations states:

“(a) Vocational nurse programs shall include theory and correlated clinical

experience.

(b) The curriculum content shall develop the knowledge, skills, and abilities

necessary to care for patients of all ages in current health care settings.

(c) Curriculum content shall be taught in a sequence that results in

students’ progressive mastery of knowledge, skills, and abilities.”

Violation # 4: Board records substantiate the program’s approved curriculum includes theory and correlated clinical experience.

The program failed to provide theory and correlated clinical experience

for all students as presented in the approved curriculum. Based on

multiple student complaints and a review of documents the program

director submitted, the NEC noted that all students completed clinical

experience after the June 2018 completion date.


Section 2534(b) of the Vocational Nursing Rules and Regulations states:

“Schools shall have clinical facilities adequate as to number, type, and variety of patients treated, to provide clinical experience for all

students in the areas specified by Section 2533. There must be

available for student assignment, an adequate daily census of

patients to afford a variety of clinical experiences consistent with

competency-based objectives and theory being taught.”

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Violation # 5: Based on submitted clinical rotation calendars, the program lacks

adequate clinical facilities that provide a variety of clinical experiences

consistent with competency – based objectives and theory being taught

sufficient for enrolled students.


On September 4, 2018, the Executive Officer rescinded the programs ongoing admissions to admit two full time classes of 30 students per calendar year to replace graduating class, requiring the program to admit no additional classes without prior approval by the Board. On September 24, 2018, the assigned Nursing Education Consultant received additional complaints against the Hacienda La Puente Adult Education Vocational Nursing Program. It was determined that Board staff would conduct an onsite inspection. Report of Unannounced visit On October 23-25, 2018, representatives of the Board made an unannounced site visit to Hacienda La Puente Adult Education Vocational Nursing Program. During the three-day visit, the representatives assessed the physical resources for the program, inspected records for recently graduated and currently-enrolled students, and facilitated discussions with cohort(s) of students, faculty, and the program director. The campus has adequate parking for all students, faculty and staff. The campus is clean. The campus has several buildings as the school has several programs other than the vocational nursing program located at this campus. The building(s) are separate from the from each other. The classrooms and one lab are in a building at the end of rows of buildings. Each building has four class rooms/lab. The director of the vocational nursing program has her office in the main building away from the classrooms and lab. Her office is in the administration building.

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Resources Library The Hacienda La Puente Adult Education Vocational Nursing Program library is located in the administration building. The students have access to the library and rooms in which they can study when the administration building is open: Monday through Thursday 8:00 am to 7:00 pm, and Friday 8:00 am to 4:00 pm.

Computer Labs The program has one computer lab which is shared with all other programs on the campus. The vocational nursing students do not have access to computers throughout the lecture day. There are twenty-seven computers in the resource area. There is also a computer/resource staff available while lab is open. Classes do not reserve the computer lab and do not have access to the computer lab during lecture time. There were three to four computers in the back of all vocational nursing classrooms, but not enough computers for an entire class to use during class time.

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AgAgenda enda IItem tem ##15.8.2 15.B.2

Classrooms There are three classrooms for the vocational nursing program. The vocational nursing program shares all classrooms and lab space with the psychiatric technician’s program. The class room contains a white board, LCD projector, podium with computer and a DVD player. The student seating with desks is adequate for up to 25 - 29 students. There are extra desks which can be brought in the classroom if needed.

Skills labs The skills lab was not organized. The skills lab contained seven beds and mannequins were scattered throughout. Clinical equipment was in boxes. The disorganization would not allow instructors to use the skills labs for student evaluation. Mannequins were stacked on other mannequins. There was no order or organization of lab equipment noted. The program director stated that the program had just relocated their skills lab and classrooms to this different building and had not had time to organize equipment. This was the only skills lab which was shared by both the vocational nursing and the psychiatric technicians program.

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Faculty Supplies The campus does not have a designated faculty room. The instructors do have a desk, computer, and office supplies in each of the classrooms. There is a copy machine available to all faculty members inside the administration building. Faculty Interviews Two faculty members were interviewed. They both stated that they enjoyed working for Hacienda La Puente vocational nursing program. The instructor’s complaints were related to not being able to pass medications in the clinical facilities the way she “thought” the student should be able to pass medications. There was also some concern with students going to different clinical sites with different instructors in the same level and the lack of consistency. Student Interviews Two groups of students were interviewed. Several students from the vocational nursing 1 class as well as several students from the vocational nursing 2 class were interviewed. During the student interviews, students stated that they would go to health fairs for their clinical make up without an instructor present. Several students made positive comments about instructors and several students made comments about the need to obtain more or different clinical sites. Other Considerations: During the October 23-25, 2018, visit none of the five previous violations were corrected.

Section 2526(a) (7) of the Vocational Nursing Rules and Regulations states:

“The institution shall apply to the Board for approval. Written documentation shall be prepared by the director and shall include: . . . (7) Instructional Plan.”

Violation # 1: The program failed to present instruction consistent with the Board-

approved instructional plan which documents correlation between theory and clinical content on a weekly basis. On August 1, 2018, the program director informed the Board representative that the cohort beginning in June 2017 and completing in June 2018 had not finished their clinical instruction at the time of completion of the program. The students in that cohort continued with supervised clinical experience after graduation to compete clinical hours. According to the approved instructional plan, the curriculum consists of 48 weeks of theory and clinical instruction. Both the theory and clinical instruction were to run congruently.

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AgAgenda enda IItem tem ## 115. 5.B.2 8.2

The cohort that began January 2018, was to start Level 2 clinical experience in July 2018. In July 2018, there were not enough instructors or clinical sites for the students to obtain clinical experience. The students were placed in the classroom instead of in clinical sites.

The students must sign in and out for clinical experience. The students must write down time in and time out by each student’s name on a typed list of names and then the instructor enters this information into the computer. The program director, along with the administrator, stated that all times in and out appeared to be in one person’s handwriting therefore actual hours in clinical could not be confirmed. The program director confirmed the students in the July 2017 cohort were receiving academic instruction after their curriculum ended in June 2018. The program director also confirmed that the January 2018 cohort was deficient in their clinical hours. She is in the process of working with the NEC to determine exactly how many hours these students need to make up and to develop a plan to allow these students to make up the clinical hours.

Status: This violation is not corrected

Section 2526 (a) (8) of the Vocational Nursing Rules and Regulations states,

“The institution shall apply to the Board for approval. Written documentation shall be prepared by the director and shall include: … (8) Evaluation methodology for curriculum

Violation # 2: The program submitted its policy for the evaluation methodology for

curriculum. The program failed to follow that plan.

Hacienda La Puente Adult Education, Vocational Nursing Program’s evaluation methodology for curriculum includes the following items:

“All students will be asked to evaluate instructors, clinical facilities and clinical staff after each term and overall program prior to graduation and the director will review of all student evaluations.”

The program was unable to produce documents at the time of the visit which substantiate they are following their Board-approved evaluation methodology plan for curriculum.


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Section 2530(i) of the Vocational Nursing Rules and Regulations states:

“The school shall evaluate student performance to determine the need for remediation or removal from the program.”

Violation # 3: The program was not able to produce documentation of remediation for

any students who were removed from the program for the current two cohorts or the cohort which graduated in June 2018.

There were complaints by several students who graduated in June 2018 that the VN 2 instructor kept a separate grade book. The program director nor the administrator could produce this gradebook during the visit.


Section 2533(a)(b)(c) of the Vocational Nursing Rules and Regulations states:

(a) Vocational nurse programs shall include theory and correlated clinical experience. (b) The curriculum content shall develop the knowledge, skills, and abilities necessary to care for patients of all ages in current health care settings. (c) Curriculum content shall be taught in a sequence that results in students’ progressive mastery of knowledge, skills, and abilities.”

Violation # 4: Board records substantiate the program’s approved curriculum includes theory and correlated clinical experience. The program failed to provide theory and correlated clinical experience for all students as presented in the approved curriculum. Based on multiple student complaints and a review of documents, the NEC noted that all students completed clinical experience after the June 2018 completion date.

Per the interviews with the students and the instructors, the VN 2 class which started second level in July were left in the classroom and not able to obtain clinical experience because there were not enough clinical sites and instructors. When the program director was approached with this information she stated that she had lost one instructor and the other instructors had not completed the County USC orientation process for clinical instructors. The students did not go to clinical sites during July and part of August 2018. The VN 2 class finished Obstetrics theory in September 2018 and obtained Obstetrics clinical experience during the week of October 22nd. Half of the students obtained Obstetrics clinical experience for three weeks while the other half of the students obtained medical-surgical

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clinical experience for three weeks. Then the students switched. The second group will not be obtaining Obstetric clinical experience until almost two months after finishing up the theory component of Obstetrics.



“Schools shall have clinical facilities adequate as to number, type, and variety of patients treated, to provide clinical experience for all students in the areas specified by Section 2533. There must be available for student assignment, an adequate daily census of patients to afford a variety of clinical experiences consistent with competency-based objectives and theory being taught. Clinical objectives which students are expected to master shall be posted on patient care units utilized for clinical experience.”

Violation # 5: The program director scheduled vocational nursing students to obtain

clinical experience at a clinical site approved only for the Psychiatric Technicians Program.

Based on submitted clinical rotation calendars, the program lacks adequate clinical facilities that provide an adequate daily census to afford a variety of clinical experiences consistent with competency – based objectives and theory being taught sufficient for enrolled students.


During the October 23 -25, 2018, sixteen additional violations were identified, bringing the total number of violations to twenty-one. Section 2882 of the Vocational Nursing Rules and Regulations states:

“The course of instruction of an approved school of vocational nursing shall consist of not less than the required number of hours of instruction in such subjects as the board may from time to time by regulation determine, together with the required number of hours in the care of medical, surgical, obstetrical patients, sick children, and such other clinical experience as from time to time may be determined by the board.”

Violation # 6: The program has one pediatric clinical site, Los Angeles County USC

Medical Center. The program was informed by the Medical Center that the current Level 2 group will not be able to rotate through Los Angeles County USC Medical Center for pediatric rotation. Based on that information the program currently does not have pediatric clinical sites.

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“The institution shall apply to the Board for approval. Written documentation shall be prepared by the director and shall include:

. . . (11) Evaluation methodology of clinical facilities.” Violation # 7: The program has submitted an evaluation methodology for curriculum

which included evaluation of the clinical sites. The program failed to follow their evaluation methodology plan for curriculum.

Hacienda La Puente Adult Education, vocational nursing program’s evaluation methodology for curriculum includes the following items.

“All students will be asked to evaluate instructors, clinical facilities and clinical staff after each term and overall program prior to graduation and the director reviews all student evaluations.”

The program was unable to produce documents at the time of the visit which substantiate they are following their Board-approved evaluation methodology plan related to clinical facilities.



“The institution shall apply to the Board for approval. Written documentation shall be prepared by the director and shall include: … (12) Admission criteria.”

Violation # 8: Board records confirm the program has approved policies for admission

of applicants to the program. Examination of student files during the program inspection indicate that students who scored below the stated minimum passing score on the TABE entrance exam, as listed in the college admissions catalog, were admitted to the program. It was also identified that students who had not met the minimum requirement of 12th grade equivalency were admitted into the program.


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Section 2526(a) (17) (A) of the Vocational Nursing Rules and Regulations states: “The institution shall apply to the Board for approval. Written documentation shall be prepared by the director and shall include: … (17) (A) Credit Granting”

Violation # 9: Examination of student files during the program inspection indicated that students who had Certified Nursing Assistant certificates were not given credit nor were there documents stating they had waived the credit.


Section 2527 (a) of the Vocational Nursing Rules and Regulations states:

“The Board shall require such reports by schools and conduct such investigations as necessary to determine whether or not accreditation will be continued.”

Violation # 10: After the Board received a complaint in July 2018 a letter was sent to

the program director requesting a response to the complaint. The due date for this response was September 21, 2018. Documents were received from the program on September 25, 2018. The documents contained locations and times of clinical experience for existing students. When the NEC arrived at each of the two clinical sites during the unannounced visit, the students were not at either location. Based on that finding the documents received from the program director were not true and inaccurate.

During the visit, the NEC requested many documents for review. The following requested documents were not provided as requested:

• Term 2 Syllabus

• Term 2 grade book

• Facility files.



“A school shall report to the Board within ten days of the termination of a faculty member.”

Violation # 11: Upon request, the program provided a list of current faculty members on

September 25, 2018. The list included an instructor who had been terminated in May 2018. No notification of termination of this instructor had been given to the BVNPT.

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Section 2527(c) of the Vocational Nursing Rules and Regulations states:

“A material misrepresentation of fact by a vocational nursing program in any information submitted to the Board is cause for denial or revocation of approval or provisional approval.”

Violation # 12: The program was requested to give to the Board the following

documents:

Faculty Student Clinical Assignment Form, Student Clinical Rotation Schedule for all students in all terms, and Current Faculty/Facility Forms. According to the forms provided, students were in clinical sites on specific days and at specific locations with specific instructors. The information documented was false. The NEC went to two of the identified clinical sites where students were to be during clinical hours. No students were at either clinical site. One group of students was sitting in the classroom instead of going to the clinical site due to a lack of instructors and a lack of approved clinical sites. Documentation provided by the program director regarding program faculty included instructors who were no longer working for this program.



“Each vocational nursing program shall have one faculty member, designated as director who meets the requirements of subsection (c)(1) herein, who shall actively administer the program. The director is responsible for compliance with all regulations in Chapter 1, Article 5 (commencing with Section 2525 et seq.).”

Violation # 13: Board documents confirm this program has a director. This director is

not actively administering the program as evidenced by the program’s noncompliance with multiple sections of the Vocational Nursing Practice Act. During this unexpected visit, there were twenty-one violations. The program director was aware of many of these violations and had not initiated correction.


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Section 2530(a) of the Vocational Nursing Rules and Regulations states:

“The Program shall have sufficient resources, faculty, clinical facilities, library, staff and support services, physical space, skills laboratory and equipment to achieve the program’s objectives.”

Violation # 14: The program currently has three clinical sites for the vocational nursing

program. The program currently does not have a pediatric clinical site.

The program has three instructors plus the director. When each of the cohorts are split into two groups for clinical there are not enough instructors to allow the students to meet their objectives. In the skills lab, there was no order or organization of lab equipment noted. The skills lab contained seven beds and mannequins but they were not prepared for student use. Mannequins were stacked on other mannequins. There were boxes of clinical equipment found throughout the lab. The identified disorganization would not allow an instructor to use the skills labs for student evaluation of any kind. The program director stated that the program had just relocated their skills lab and classrooms to this different building and had not had time to organize things. This was the only skills lab and it was shared by both the vocational nursing and the psychiatric technicians program.



“Regular faculty meetings shall be held. Minutes shall be available to the Board's representative.”

Violation # 15: According to the 2016 – 2017 Annual report, the program states they

have monthly staff meetings. At the time of the visit, the program director was not able to produce documents to substantiate monthly staff meetings.


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Section 2530(c) of the Vocational Nursing Rules and Regulations states:

“Clinical faculty shall have no other responsibilities during the hours assigned to the instruction of students.”

Violation # 16: The program director stated that at the time she is scheduled to be the

instructor in skills lab, she is also responsible for orientating new staff, and for fulfilling her program director duties.


Section 2530(e) of the Vocational Nursing Rules and Regulations states:

“Each instructor shall have a daily lesson plan which correlates theory and practice offered to the student. A copy of this plan shall be available to the director”

Violation # 17: During the interview with two instructors they were both asked if they had

a daily lesson plan which correlates theory and practice offered to the students. Neither of the staff stated they had a daily lesson plan.


Section 2530(f) of the Vocational Nursing Rules and Regulations states: “The program’s instructional plan shall be available to all faculty.” Violation # 18: During the interviews with both instructors they stated they knew there

was an Instructional Plan (IP), but neither were 100 percent sure of its location.


Section 2530(h) of the Vocational Nursing Rules and Regulations states:

“Each school shall have an attendance policy approved by the Board. The policy shall include but not be limited to, criteria for attendance and the specific course objectives for which make-up time is required. Acceptable methods for make-up include:

(1) Theory: case studies, independent study, written examination, attendance at seminars or workshops, auto-tutorial laboratory, and research reports.

(2) Clinical: performance evaluation in skills laboratory or additional time in the clinical area with clients/patients.”

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Violation # 19: The program has documentation for some of the students’ make-up for missed clinical experience. One completed form stated the student watched videos to make up clinical time. Another form stated the student completed a study guide for clinical time missed. Other forms were only half-completed and not all forms contained missed clinical objectives. The assigned date for clinical make-up as well as documentation by the instructor that the make-up was completed were also missing on some forms.

When speaking to students, several students stated that make up for clinical was done at a community health fair. They were required to volunteer at the community health fair to make up the hours. No instructor was at the community health fair. There was no correlation to missed objectives.


Section 2534(a) of the Vocational Nursing Rules and Regulations states:

“Schools shall apply on a form provided by the Board for approval of each clinical facility prior to use.”

Violation # 20: During the program inspection there was an instructor who is not Board-

approved in the skills lab with a group of students. This group of students was supposed to be at a clinical site, but had been brought to the skills lab/classroom instead.


Section 2534(d) of the Vocational Nursing Rules and Regulations states:

“For supervision of clinical experience, there shall be a maximum of 15 students for each instructor.”

The current number of Board-approved faculty totals three, including the program director. The director has 80 percent administrative duties and 20 percent teaching duties. Of the total faculty, one instructor is part time and one is full time. Both instructors and the program director are designated to teach clinical. Based upon a maximum enrollment of 47 students, four instructors are required for clinical supervision. The utilization of faculty at clinical facilities is such that clinical instruction is not covered adequately.

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Violation # 21: The program does not have enough Board-Approved faculty designated to teach in the clinical area.


Recommendations: 1. Place the Hacienda La Puente Adult Education Vocational Nursing Program on

provisional approval for the two-year period beginning February 22, 2019; and issue a notice to the program to identify specific areas of non-compliance and requirements for correction as referenced in Section 2526.1 of the California Code of Regulations.

2. Require the program to correct existing twenty-one violations identified during the onsite inspection and submit documentation of corrections of all violations no later than May 1, 2019.

3. Require the program to admit no additional classes without prior approval by the Board.

4. Require the program to submit a report to the Board by seven months, no later than

September 2, 2019, and twenty-one months, no later than November 1, 2020. The report must include a comprehensive analysis of the program, timeline for implementation, and the effect of employed interventions. The following elements must be addressed in the analysis.

a. Admission and Screening Criteria. b. Terminal Objectives. c. Evaluation of the current curriculum to include:

1. Program Objectives 2. Instructional Plan 3. Theory and Clinical Objectives for each course 4. Lesson Plans for each course 5. Evaluation of correlation of theory and clinical content 6. Textbooks

d. Evaluation of the following student policies: 1. Attendance Policy 2. Remediation Policy 3. Evaluation of Student Achievement 4. Credit Granting

e. Evaluation of available clinical facilities approvals to determine adequacy in number and variety of patients to accommodate current and projected students and to allow opportunity for the students to meet clinical objectives.

f. Evaluation of theory and clinical faculty. g. Evaluation of theory presentations. h. Evaluation of student achievement.

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5. Require the program to provide no less than one (1) instructor for every ten (10)

students in clinical experiences.

6. Require the program to comply with all approval standards in Article 4 of the Vocational Nursing Practice Act, commencing at Business and Professionals Code, section 2880, and Article 5 of the Board’s Regulations, commencing at California Code of Regulations, Title 16, section 2526.

7. Require the program to demonstrate incremental progress in correcting the

violations. If the program fails to satisfactorily demonstrate incremental progress, the full Board may revoke the program’s approval.

8. Place the program on the Board’s February 2021 agenda for reconsideration of

provisional approval.

Rationale: As noted previously, published examination statistics confirm the program’s compliance with regulations for all eight of the previous eight quarters.

The program, when given the opportunity to fix the original five violations, failed to do so. On September 5, 2018, the program was given a list of violations. During the site visit made October 23-25, 2018, not only were none of the original five violations corrected, but there were sixteen additional violations identified. A total of twenty-one violations remain uncorrected at this program. Given the foregoing, provision approval is recommended.

Board staff will continue to monitor the program by tracking its licensure examination pass rate quarterly, reviewing the program’s Annual Reports, and performing accreditation surveys every four years.

Attachment A: History of Prior Board Actions

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Agenda Item #15.B.2., Attachment A

HACIENDA LA PUENTE ADULT EDUCATION

VOCATIONAL NURSING PROGRAM

History of Prior Board Actions

• In September 1980, the Board approved commencement of a part – time vocational nursing program at La Puente Valley Adult School, La Puente, California, with an initial class of 30 students.

• In April 1982, the Board approved initial full accreditation of the La Puente Valley Adult School Vocational Nursing Program.

• In January 1985, the Board approved the program’s major curriculum revision. The program’s revised curriculum included 1,578 hours (600 theory hours; 978 clinical hours).

• In January 1991, the Board considered the report of the survey August 14-17, 1990 survey visit. The Board approved the program’s continued accreditation.

• In April 1991, the Board ratified the consultant’s approval of the program’s revised curriculum for 1,530 hours (576 theory hours; 954 clinical hours).

• On August 17, 1995, a new program director was approved.

• In May 1996, the Board ratified the consultant’s approval of the program’s revised instructional plan for a part – time class to a 48-week full – time class. The total hours remain the same.

• On November 16, 2001, the Board approved continued full accreditation of the Hacienda La Puente Vocational Nursing Program for the four-year period from November 16, 2001, to November 16, 2005, and issued a certificate accordingly.

• On November 8, 2002, the Board approved the program’s request to increase the class size from 30 to 45 students for the class commencing January 6, 2003 only.

• On November 14, 2003, the Executive Officer approved the program’s request to admit a class of 15 students commencing January 5, 2004 only.

• On April 14, 2004, the Executive Officer approved the program’s request to admit an additional class of 15 students commencing June 28, 2004 only. The proposed class

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will graduate June 15, 2005. The students in this class are Kaiser Permanente employees sponsored by a partnership on Kaiser and the employee unions.

• On September 16, 2005, the Executive Officer approved continued full accreditation for the Hacienda La Puente Vocational Nursing Program for the four – year period from September 16, 2005, to September 15, 2009, and issued a certificate accordingly. Additionally, the program’s request to admit an additional 15 students to the January class effective January 9, 2006 was approved.

• On July 15, 2009, the program submitted its Program Records Survey for continued accreditation.

• On September 3, 2009, the Executive Officer approved continued full accreditation for the Hacienda La Puente Adult Education Vocational Nursing Program for a four-year period from September 16, 2009 through September 15, 2013, and the Board issued a certificate accordingly.

• On August 18, 2016, a new program director was approved.

• On May 11, 2018, the Executive Officer adopted the following recommendations:

• Continue full approval for the Hacienda La Puente Adult Education Vocational Nursing Program for a four-year period from September 16, 2017 through September 15, 2021, and issue a certificate accordingly.

• Continue approval of the program’s ongoing admissions to replace graduating classes, only, with the following stipulations:

• No additional classes are added to the program’s pattern of admissions without prior Board approval. The program’s pattern of admissions will include admission of one (1) class of 30 students two (2) times per year, only.

• The director documents that adequate resources, i.e. faculty and facilities, are available to support each admitted class of students.

• The program maintains an average annual pass rate that is compliant with Section 2530 (l) of the Code.

• On September 4, 2018, the Executive Officer adopted the following recommendations:

• Rescind approval of Hacienda La Puente Adult Education Vocational Nursing Program’s ongoing admission of two full-time classes of 30 students each calendar year to replace graduating students, only, effective immediately.

• Require the program to admit no additional classes without prior approval by the Board.

• Require the program, when requesting approval to admit students, to:

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• Submit all documentation in final form, using the forms provided by the Board, no later than two months prior to the requested start date for the class.

• Provide documentation that adequate resources, i.e. faculty and facilities, are available to support each admitted class of students.

• Require the program to: Correct all identified violations, and Submit a report by September 15, 2018, that substantiates the adequacy of program resources, including, but not limited to:

• Clinical facilities and instructors that can provide a variety of clinical experiences that are consistent with the competency-based objectives and theory in the Board-approved instructional plan, and

• Number of faculty and facilities adequate for the number of enrolled students.

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