Report 2019-120 All Recommendation Responses

Report 2019-120: Board of Registered Nursing: It Has Failed to Use Sufficient Information When Considering Enrollment Decisions for New and Existing Nursing Programs (Release Date: July 2020)

Recommendation #1 To: Registered Nursing, Board of

To better ensure that California has an appropriate number of nurses in the future, BRN should do the following by January 1, 2021: revise the scope of work of its contract for workforce forecasting services to direct the contractor to incorporate regional analyses.

Annual Follow-Up Agency Response From October 2021

A new contract with UCSF was executed and the scope of work included a contract deliverable for regional analyses.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

We have reviewed the revised scope of work of its contract for registered nurse (RN) surveys and forecasts. We found that it includes it includes a task of developing regional projections of future supply and demand of RNs, summarizing that information in a report, and comparing those supply and demand projections with projections published by other organizations.

1-Year Agency Response

The BRN drafted the scope of work for a proposed contract with UCSF. The scope of work includes regional analyses as a contract deliverable. The proposed contract is awaiting required approvals from, including but not limited to, the Office of State Printing and Department of General Services. The proposed contract has a start date of July 1, 2021.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

The BRN will include in all future workforce forecasting contracts regional analyses as a contract deliverable. The BRN anticipates beginning the contract process for the next contract delivering forecasting services in January 2021.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

The BRN appreciates and concurs with the CSA's substantive recommendation to revise the contract's scope of work. However, as stated in the original response, BRN has a current contract for workforce forecasting services in place with an end date of June 30, 2021, and work has already been performed for this contract period. The BRN will ensure that all future contracts will include regional analyses as a contract deliverable.

The 2019 "Forecasts of the Registered Nurse Workforce in California" report has been completed and is posted to the BRN website. Through the data collection efforts for this report, UCSF collected regional information which is relied upon by the BRN and the Board when making decisions regarding pre-licensure nursing school programs. BRN also worked with UCSF to launch the BRN School Survey Interactive Data Portal. This portal was launched on August 21, 2020, and displays data about nursing school programs and their students and faculty, and assigns them into ten regions. Finally, DCA's website contains an Open Data Portal which shows licensing statistics by county as well as an interactive map which displays the distribution of DCA's active licensee population across all 58 California counties. The map also shows the annual change in the active licensee population from year to year for each of these counties. Through these aforementioned tools regional information is publicly available on its website and relied upon the Board.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #2 To: Registered Nursing, Board of

To better ensure that California has an appropriate number of nurses in the future, BRN should do the following by January 1, 2021: ensure that the governing board's enrollment decisions and other actions adequately take into consideration the regional analyses in BRN's future workforce forecasts. Specifically, it should amend its policies to require that when its staff present information to the education committee and the governing board to inform them on pending enrollment decisions, staff should include relevant information related to BRN's most recent forecast of the nursing workforce.

6-Month Agency Response

The BRN updated the ELC Liaison manual and the New Hire Orientation manual. Additionally, the BRN completed the NEC training and sent an email reminder to all NECs that the policy is to ensure that the AIS contained in the Board meeting materials and in presentations to the Board by NECs contain relevant information related to BRN's most recent forecast of the nursing workforce, and other relevant regional data, so that such information may be taken into consideration when making enrollment decisions.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

We reviewed the sections of the ELC Liaison manual and New Hire Orientation manual that BRN provided, as well as its email communication to nursing education staff requiring them to include the relevant regional forecast information and notifying them of the revisions to the manuals. If followed, these policy changes should better ensure the governing board's enrollment decisions and other actions adequately take into consideration the regional analyses in BRN's future workforce forecasts.

60-Day Agency Response

BRN developed policies to require that relevant information related to BRN's most recent forecast of the nursing workforce, and other relevant regional data, be included in agenda item summaries (AIS) contained in board meeting materials, and in presentations to the board by NECs, so that such information may be taken into consideration when making enrollment decisions. BRN is in the process of updating the Education/Licensing Committee (ELC) Liaison manual and the New Hire Orientation manual accordingly. Also, BRN will hold additional training sessions with NECs to ensure all NECs are trained on this updated policy.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #3 To: Registered Nursing, Board of

To ensure that nursing education staff members provide complete information to the governing board when it is considering enrollment decisions, by January 1, 2021, BRN should establish in policy the specific information that its staff should present to the education committee and governing board, including data about clinical facilities that nursing programs use for placements, the content areas for which the programs use those facilities, and the total number of available placement slots and the risk of clinical displacements at the facilities.

6-Month Agency Response

The BRN previously amended the optional clinical facility approval form (EDP-P-18) and the EDP-I-15 Instruction form and presented them to the Deans and Directors at the California Organization of Associate Degree Nursing/California Association of College Nursing (COADN/CACN) meeting on October 7, 2020. The BRN requested all approved prelicensure programs update each of their EDP-P-18s to reflect the current up-to-date information with a goal to be completed by January 2021. The BRN updated the ELC Liaison manual and the New Hire Orientation manual to reflect these amendments. Additionally, the EO held training sessions for the Deans and Directors where questions were asked and answered on Monday December 22nd, Tuesday December 23rd, and Thursday December 31st after it was expressed that there was confusion around the completion of these forms and whether the BRN had the authority to request and collect this information.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

We reviewed documentation BRN provided and believe its guidance documentation for the nursing education staff, if followed, would ensure they provide complete information to the governing board. Specifically, we reviewed the Agenda Item Summary template used for preparing board meeting agendas and the checklist of information that must be provided for ELC and Board meetings and found they require the nursing education staff to provide information that addresses our recommendation. However, as Recommendation 6 states, once it has compiled and aggregated in a database information about clinical capacity, BRN should also require its nursing education staff to provide that information to the governing board.

60-Day Agency Response

BRN has amended the optional clinical facility approval form (EDP-P-18) to capture annual capacity estimates from clinical facilities, as well as annual clinical placement needs of programs. BRN provided training with the NECs during the Joint Nursing Education Consultant (JNEC) meeting on September 3, 2020, on the revised EDP-P-18. The BRN will update the ELC Liaison and NEC New Hire Orientation manuals to ensure that they reflect the updated policies. Additionally, the Director's Handbook has the updated EDP-P-18. The changes to the Director's Handbook are scheduled to be presented at the 2020 CACN-COADN Joint Fall Conference during the BRN session. Once these new forms are presented, the NECs will start the work to have all approved pre-licensure programs update each of their EDP-P-18s to reflect the current up to date information.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #4 To: Registered Nursing, Board of

To ensure that BRN is using up-to-date, accurate, and objective information to inform the governing board's enrollment decisions and to assess clinical capacity for student placements, by April 1, 2021, BRN should do the following: update its clinical facility approval form to capture annual capacity estimates from clinical facilities, as well as annual clinical placement needs of programs.

6-Month Agency Response

The BRN previously amended the optional clinical facility approval form (EDP-P-18) and the EDP-I-15 Instruction form. These amended forms were presented to the Deans and Directors at the COADN/CACN Meeting on October 7, 2020. The BRN requested all approved prelicensure programs update each of their EDP-P-18s to reflect the current up-to-date information with a goal to be completed by January 2021.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

We have reviewed the revised clinical facility approval form, the presentation at COADN/CACN, and BRN's communication to prelicensure programs. The form now includes annual clinical capacity estimates as well as annual clinical placement needs of programs.

60-Day Agency Response

BRN has amended the optional clinical facility approval form (EDP-P-18) to capture annual capacity estimates from clinical facilities, as well as annual clinical placement needs of programs. Additionally, the BRN has updated the Director's Handbook to include the updated EDP-P-18 and clinical facility approval - instruction (EDP-I-15) forms. The updated EDP-I-15 form outlines the process for notifying the BRN within 90 days of any changes in clinical placements including the cancellation of a clinical rotation and the request for annual verification of clinical placements.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #5 To: Registered Nursing, Board of

To ensure that BRN is using up-to-date, accurate, and objective information to inform the governing board's enrollment decisions and to assess clinical capacity for student placements, by April 1, 2021, BRN should do the following: revise its regulations to require nursing programs to report any changes they make to their use of clinical facilities within 90 days of making a change and report annually if the program has made no changes.

Annual Follow-Up Agency Response From October 2022

A regulation package amending CCR, Title 16, section 1427 was approved by Office of Administrative Law pursuant to section 11349.3 of the Government Code. This regulatory action becomes effective on January 1, 2023. This update now requires nursing programs to report changes made to the use of their clinical facilities within 90 days of making the change and to report annually by December 31 of each year that the Board's report is accurate and notify the Board of any required corrections or additions.

A regulation package amending CCR, Title 16, section 1432 was approved by Office of Administrative Law pursuant to section 11349.3 of the Government Code. This regulatory action becomes effective on January 1, 2023. This rulemaking package makes three substantial changes. First, in 16 CCR 1423 the board makes concealing material facts from the board a cause for denial of an application or revocation of an approved program. Second, in section 1432, the board requires nursing programs applying to add new locations to use an existing form (EDP-I-01 Rev 3/10), updated in this rulemaking package to EDP-1-01 Rev 10/22. Third, in section 1432, the board requires nursing programs to apply for approval for any increase in enrollment numbers. The board also makes non-substantive edits to Section 1421(a) to update the name of the Form EDP-I-01.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

We reviewed the revised regulations and the final approval by the Office of Administrative Law. The revised regulations implement our recommendation.

Annual Follow-Up Agency Response From July 2022

A regulation package proposing to amend CCR, Title 16, section 1427 is in process and as written will require nursing programs to report changes made to the use of their clinical facilities within 90 days of making the change and to report annually if the program has made no changes. On May 12, 2022, to provide further clarification, the Board withdrew the package from OAL and continued to work with DCA and OAL to update the text. The modified text for CCR, Title 16, section 1427 as noticed was approved by the Board on June 23, 2022, and the Board directed staff to take all steps necessary to complete the rulemaking process, including authorizing the Executive Officer to make any non-substantive changes to the proposed regulations necessary to complete rulemaking process and filing the final rulemaking package with OAL.

A regulation package proposing to amend CCR, Title 16, section 1432 was submitted to OAL for publication on November 12, 2021. A public hearing was held on January 20, 2022, with comments and responses being compiled. The updated regulation that addresses changes to an approved program, clarifies the process for approval of a new campus or location and specifies the need for prior Board approval for any increase in total annual enrollment, or any change in the frequency, timing, or number of new student admissions for each Board approved nursing program or degree option.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From October 2021

The regulation packages proposing to amend CCR, Title 16, sections 1427 and 1432 to require nursing programs to report any changes they make to their use of clinical facilities within 90 days of making the change and report annually if the program has made no changes continues to be in process with the Department of Consumer Affairs and the Board of Registered Nursing.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

1-Year Agency Response

A regulation package is currently being reviewed by DCA. This regulation package proposes to amend CCR, Title 16, sections 1427 and 1432 to require nursing programs to report any changes they make to their use of clinical facilities within 90 days of making the change and report annually if the program has made no changes.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

The BRN commenced the promulgation of a regulation package which proposes to amend CCR, Title 16, sections 1427 and 1432 to require nursing programs to report any changes they make to their use of clinical facilities within 90 days of making the change and report annually if the program has made no changes.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

BRN has amended the EDP-P-18 and EDP-I-15 forms to capture annual capacity estimates from clinical facilities, as well as annual clinical placement needs of programs. The BRN has updated the Director's Handbook to include the updated EDP-P-18 and clinical facility approval - instruction (EDP-I-15) forms. The updated EDP-I-15 form outlines the process for notifying the BRN within 90 days of any changes in clinical placements including the cancellation of a clinical rotation and the request for annual verification of clinical placements.

Additionally, BRN is exploring if the regulatory changes referenced above can be included in a current regulations package already in development. If this is not possible, BRN will commence a new regulations package on or before April 1, 2021.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #6 To: Registered Nursing, Board of

To ensure that BRN is using up-to-date, accurate, and objective information to inform the governing board's enrollment decisions and to assess clinical capacity for student placements, by April 1, 2021, BRN should do the following: compile and aggregate the information from the facility approval forms into a database and take reasonable steps to ensure that the information is accurate and current.

Annual Follow-Up Agency Response From October 2023

The BRN continues to work in partnership with the Office of Information Services (OIS) to refine the technological tool that allows BRN to compile and aggregate clinical facility and nursing program specific information obtained from the updated clinical facility approval forms while ensuring data integrity and functionality for internal and external stakeholders. Upon completion of the testing phases by internal and external stakeholders, OIS and BRN will move the tool into production. Documents for training are in development. A CFA flow chart with related training documents has been completed pending any revisions from testing.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From July 2023

The Board of Registered Nursing (BRN) continues to work in partnership with the Office of Information Security (OIS) to refine the technological tool that allows BRN to compile and aggregate clinical facility and school specific information obtained from the updated clinical facility approval forms while ensuring data integrity and functionality for internal and external stakeholders. Additionally testing and validation was required which included, but was not limited to, external stakeholder testing. Additional design changes/modifications were required, and further testing was necessary; therefore, a delay in implementation has occurred.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From October 2022

The Board of Registered Nursing (BRN) continues to work in partnership with the Office of Information Services (OIS) to refine the technological tool that allows BRN to compile and aggregate clinical facility and nursing program specific information obtained from the updated clinical facility approval forms while ensuring data integrity and functionality for internal and external stakeholders. On September 27, 2022, the Clinical Facility Approval (CFA) submission/approval portal was released to be tested. Testing was completed on October 21, 2022, by the Nursing Education Consultants (NEC) mimicking both internal and external users. This testing included completing a school submission, facility approval, and NEC approval portions. Screen shots and descriptions of issues were documented as they were discovered. Once updates and any additional testing are completed the next step is to move it into production. Documents for training are in development. A CFA flow chart with related training documents has been completed pending any revisions from testing.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From July 2022

The BRN continues to work in partnership with OIS to refine the technological tool that allows BRN to compile and aggregate clinical facility and nursing program specific information obtained from the updated clinical facility approval forms while ensuring data integrity and functionality for internal and external stakeholders. On May 20, 2022, OIS released part of the tool into a production environment so that both internal and external stakeholders could begin testing. On June 6, 2022, testing commenced for both internal and external stakeholders. Currently, five more areas require testing, and two more areas require development. As additional design changes/modifications are required further testing phases could be necessary.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From October 2021

The BRN has made progress towards full implementation and will continue its efforts to compile and aggregate the information from the facility approval forms into a database.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

1-Year Agency Response

The BRN in partnership with OIS developed and implemented a technological tool that allows BRN to compile and aggregate clinical facility and school specific information obtained from the updated clinical facility approval forms. This tool allows for the receipt of faculty data from CDPH and OSHPD. The development and testing of this tool is complete and entry and validation of clinical facility data is underway. Upon completion of the data entry and verification that the data is accurate and current, it will be posted on the BRN public facing website.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

The BRN continues to work with OIS and other internal stakeholders to explore a system that will allow BRN to compile clinical facility and school specific information and receive facility data from CDPH and OSHPD. The first phase requires the BRN to work with DCA Organizational Improvement Office (OIO) to complete a mapping of the current processes and the "could be" processes. The Charter for this project was signed on or about December 4, 2020, by BRN and OIO.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

To ensure that BRN is using up-to-date and accurate information, the NECs will request all approved pre-licensure programs update each of their EDP-P-18s to reflect the current up-to-date information with a goal to be completed by January 2021. The assigned NEC will then run an annual school facilities report for their assigned schools that the Program Director or designee will review for accuracy and provide revisions to ensure that the annual report is up-to-date every December thereafter.

The BRN began discussions with DCA's Office of Information Services (OIS) to inquire about the development of a system that would allow facility information from CDPH and OSHPD to be shared with the BRN electronically. The BRN will continue to work with OIS to explore options for a system that will allow BRN to compile clinical facility and school specific information and receive facility data from CDPH and OSHPD.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #7 To: Registered Nursing, Board of

To ensure that BRN is using up-to-date, accurate, and objective information to inform the governing board's enrollment decisions and to assess clinical capacity for student placements, by April 1, 2021, BRN should do the following: annually publish clinical capacity information on its website for public use.

Annual Follow-Up Agency Response From October 2023

Utilizing the technological tool discussed in Recommendation 6 that allows BRN to compile and aggregate clinical facility and nursing program specific information and comparing it with data from the Department of Health Care Access and Information's (HCAI) list of health care facilities discussed in Recommendation 9 will provide more accurate clinical capacity information that can be used to aid the Board in making enrollment decisions. This information will be shared to the public and available on the BRN's website once the project is complete.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From July 2023

Utilizing the data discussed in Recommendation 6 and comparison data in Recommendation 9, the BRN will ensure that Board Members have accurate and current information to inform the governing Board's enrollment decisions and to assess clinical capacity for student placements. This information will be shared to the public and available on the BRN's website once the project is completed.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From October 2022

Utilizing the technological tool discussed in Recommendation 6 that allows the Board of Registered Nursing (BRN) to compile and aggregate clinical facility and nursing program specific information and comparing it with data from the Department of Health Care Access and Information's (HCAI) list of health care facilities discussed in Recommendation 9, will provide more accurate clinical capacity information that can be used to aid the Board in making enrollment decisions. This information will be shared to the public and available on the BRN's website once the project is completed.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From July 2022

Utilizing the technological tool discussed in Recommendation 6 that allows BRN to compile and aggregate clinical facility and nursing program specific information and the comparison data with HCAI's, formerly OSHPD, list of health care facilities discussed in Recommendation 9, this will provide more accurate clinical capacity information that can be used to aid the Board in making enrollment decisions. This information will be shared to the public and available on the BRN's website.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From October 2021

The BRN has made progress towards full implementation and will continue its efforts to annually publish clinical capacity information on our website. Full implementation is dependent on Recommendation 6 which is in process.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

1-Year Agency Response

Utilizing the data discussed in Recommendation 6 and comparison data in Recommendation 9 the BRN will ensure that Board members are using accurate and current information to inform the governing board's enrollment decisions and to assess clinical capacity for student placements. Upon completion of the data entry and validation discussed in Recommendation 6, the clinical capacity information will be available on the BRN's public facing website and will be updated annually.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

The BRN will continue to ensure access to up-to-date, accurate, and objective information is accessible and is used to inform the governing board for their consideration with enrollment decisions and when assessing clinical capacity for student placements. The BRN is in the process of developing a data landing page on its website that will contain all data reports, links, and portals. When collection of the updated EDP-P-18 data is complete, and the platform mentioned in the 60 day response for recommendation 6 is implemented, BRN will input this data to share a clinical capacity report on our website.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

The BRN currently publishes various reports on its website reflecting clinical needs and displacement concerns and it recently launched the BRN School Survey Interactive Data Portal which displays data about nursing schools programs and their students and faculty. These data points along with the clinical census data captured from updated EDP-P-18s will allow BRN to post clinical capacity information on its website for public use. The BRN is in the process of developing a data landing page on its website that will contain all data reports, links, and portals. When collection of the updated EDP-P-18 data is complete, and the platform mentioned in response #6 is found and implemented, BRN will input this data to share a clinical capacity report on our website.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #8 To: Registered Nursing, Board of

To ensure that BRN is using up-to-date, accurate, and objective information to inform the governing board's enrollment decisions and to assess clinical capacity for student placements, by April 1, 2021, BRN should do the following: immediately discontinue its practice of having nursing programs seek statements of support or opposition from neighboring nursing programs when considering requests for new programs or increased enrollment at existing programs.

60-Day Agency Response

As stated in the original response, BRN discontinued its practice of requiring nursing programs to seek statements of support or opposition from neighboring nursing programs when considering requests for new programs or increased enrollment at existing programs.

California State Auditor's Assessment of 60-Day Status: Fully Implemented

BRN has provided us documentation of the guidance it provided its staff to immediately discontinue its practice of requiring programs to seek letters of support from neighboring programs.

Recommendation #9 To: Registered Nursing, Board of

To identify additional facilities that might offer clinical placement slots, by October 1, 2021, and annually thereafter, BRN should compare its nursing program database with OSHPD's list of health care facilities. BRN should share the results of its comparison with nursing programs by publishing this information on its website.

Annual Follow-Up Agency Response From October 2023

Recommendations 6, 7, and 9 are interdependent and are being managed through one OIS build. When the tool discussed in Recommendation 6 is complete this will allow BRN to compare its nursing program database with HCAI's list of health care facilities and this clinical capacity information will be available on the BRN's public facing website. The tool will provide up-to-date data that will be validated annually as outlined in the response to Recommendation 5 via the regulatory amendment.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From July 2023

As recommendations 6, 7, and 9 are interdependent, when the tool discussed in Recommendation 6 is complete this will allow the Board of Registered Nursing (BRN) to compare its nursing program database with HCAI's list of health care facilities. The tool will provide up-to-date data that will be validated annually and will be available on the BRN's public facing website.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From October 2022

Recommendations 6, 7, and 9 are interdependent and are being managed through one Office of Information Services build. When the tool discussed in Recommendation 6 is complete this will allow the Board of Registered Nursing (BRN) to compare its nursing program database with HCAI's list of health care facilities and this clinical capacity information will be available on the BRN's public facing website. The tool will provide up-to-date data that will be validated annually as outlined in the response to Recommendation 5 via the regulatory amendment.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From July 2022

Recommendations 6, 7, and 9 are interdependent and are being managed through one OIS build. When the tool discussed in recommendation 6 is complete this will allow BRN to compare its nursing program database with HCAI's list of health care facilities and this clinical capacity information will be available on the BRN's public facing website. The tool will provide up to date data which will be validated annually as outlined in the response to recommendation 5 through the regulatory update.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From October 2021

The BRN has made progress towards full implementation and will continue its efforts to compare information in our nursing program database to OSHPD's list of health care facilities. Full implementation is dependent on Recommendations 6 and 7 which are in process.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

1-Year Agency Response

As discussed in 12-month response to Recommendation 6, the BRN continues to implement and expand a technological tool that will allow BRN to compile clinical facility and school specific information that will receive facility data from CDPH and OSHPD to allow for comparison. The development and testing for Phase 1 of this tool was completed on or about June 23, 2021. Upon completion of the data entry and validation discussed in Recommendations 6 and 7, the clinical capacity information will be available on the BRN's public facing website and will be updated annually.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

As discussed in Recommendation 6, the BRN continues to work with OIS and other internal stakeholders to explore a system that will allow BRN to compile clinical facility and school specific information and receive facility data from CDPH and OSHPD. However, until this system can be developed, the BRN shared various OSHPD reports including OSHPD's Healthcare Facilities List, Healthcare workforce, and Healthcare Utilization with the NECs. The NECs are using these reports when working with the Directors of Nursing at their assigned Schools when assisting them to find new and alternative clinical placements. This has been particularly helpful during the COVID-19 pandemic as clinicals have been displaced from most acute care healthcare facilities. These reports have been referenced by the NECs and the Program Directors when working to complete requirement b. in the DCA Waiver DCA-20-03 Nursing Student Clinical Hours and again in the newly enacted statute 2786.3 (A)(i) where it states: "The list of alternative agencies or facilities listed within 25 miles of the impacted approved nursing program, campus, or location, as applicable, using the facility finder on the Office of Statewide Health Planning and Development's website."

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

The BRN will continue to work with OIS to explore options for a system that will allow BRN to compile clinical facility and school specific information from the EDP-P-18 and receive facility data from CDPH and OSHPD. Reports from this system would be published to BRN's website. The BRN is in the processing of developing a data landing page on its website that will contain all data reports, links, and portals.

California State Auditor's Assessment of 60-Day Status: Pending

Although BRN indicated it is exploring options to develop a system to compare clinical facility information, its date of implementation is October 2021. In the meantime, we believe BRN can and should start now by comparing its nursing program database with OSHPD's list of health care facilities to identify additional facilities that might offer clinical placement slots, as we described on pages 26 and 27 of our report.

Recommendation for Legislative Action

To better inform stakeholders and the governing board's decision making, the Legislature should amend state law to do the following: require BRN to incorporate regional forecasts into its biennial analyses of the nursing workforce.

Description of Legislative Action

AB 1015 (Chapter 591, Statutes of 2021) requires BRN to incorporate regional forecasts into its biennial analyses of the nursing workforce. This bill was chaptered on October 6, 2021, and is effective January 1, 2022.

California State Auditor's Assessment of Annual Follow-Up Status: Legislation Enacted

AB 1015 (Chapter 591, Statutes of 2021) was chaptered on October 6, 2021, and is effective January 1, 2022.

Description of Legislative Action

AB 1015 (Rubio) would require BRN to incorporate regional forecasts into its biennial analyses of the nursing workforce.

California State Auditor's Assessment of 1-Year Status: Legislation Introduced

Description of Legislative Action

As of January 7, 2021, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 6-Month Status: No Action Taken

Description of Legislative Action

As of September 5, 2020, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 60-Day Status: No Action Taken

Recommendation for Legislative Action

To better inform stakeholders and the governing board's decision making, the Legislature should amend state law to do the following: require BRN to develop a plan to address regional areas of shortage identified by its nursing workforce forecast. BRN's plan should include identifying additional facilities that might offer clinical placement slots.

Description of Legislative Action

AB 1015 (Chapter 591, Statutes of 2021) requires BRN to develop a plan to address regional areas of shortage identified by its nursing workforce forecast and identify in the plan additional facilities that could offer clinical placement slots. This bill was chaptered on October 6, 2021, and is effective January 1, 2022.

California State Auditor's Assessment of Annual Follow-Up Status: Legislation Enacted

AB 1015 (Chapter 591, Statutes of 2021) was chaptered on October 6, 2021, and is effective January 1, 2022.

Description of Legislative Action

AB 1015 (Rubio) would require BRN to develop a plan to address regional areas of shortage identified by its nursing workforce forecast and identify in the plan additional facilities that could offer clinical placement slots.

California State Auditor's Assessment of 1-Year Status: Legislation Introduced

Description of Legislative Action

As of January 7, 2021, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 6-Month Status: No Action Taken

Description of Legislative Action

As of September 5, 2020, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 60-Day Status: No Action Taken

Recommendation for Legislative Action

As part of BRN's sunset review in 2021, the Legislature should consider whether the State would be better served by having BRN revise its regulations to leverage portions of the accreditors' reviews to reduce duplication and more efficiently use state resources. For example, it could consider restructuring continuing approval requirements for nursing programs that are accredited and maintain certain high performance standards for consecutive years (for example, licensure exam pass rates, program completion rates, and job placement rates). Additionally, the Legislature should consider whether and how BRN could coordinate its reviews with accreditors to increase efficiency.

Description of Legislative Action

On March 18, 2022, the Legislature held a sunset review hearing. During this hearing, the Legislature included an agenda item, "Overview of Recent State Auditor Reports on the BRN," which it linked to the recommendations from Report 2019-120. During the hearing, the Legislature discussed the overlap of BRN with national accreditors.

California State Auditor's Assessment of Annual Follow-Up Status: No Longer Necessary

Fully Implemented.

Description of Legislative Action

As of July 7, 2021, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 1-Year Status: No Action Taken

Description of Legislative Action

As of January 7, 2021, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 6-Month Status: No Action Taken

Description of Legislative Action

As of September 5, 2020, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 60-Day Status: No Action Taken

Recommendation for Legislative Action

To ensure that BRN and stakeholders have an understanding of clinical placement capacity in California, the Legislature should amend state law to require BRN to annually collect, analyze, and report information related to the number of clinical placement slots that are available and the location of those clinical placement slots within the State.

Description of Legislative Action

AB 1015 (Chapter 591, Statutes of 2021) requires BRN to annually collect, analyze, and report information related to the number of clinical placement slots that are available and the location of those clinical placement slots within the State, including, but not limited to, information about the total number of placement slots a clinical facility can accommodate and how many slots the programs that use the facility will need. Finally, the bill would require BRN to place the annual report on its website. This bill was chaptered on October 6, 2021, and is effective January 1, 2022.

California State Auditor's Assessment of Annual Follow-Up Status: Legislation Enacted

AB 1015 (Chapter 591, Statutes of 2021) was chaptered on October 6, 2021, and is effective January 1, 2022.

Description of Legislative Action

AB 1015 (Rubio) would require BRN to annually collect, analyze, and report information related to the number of clinical placement slots that are available and the location of those clinical placement slots within the state, including, but not limited to, information concerning the total number of placement slots a clinical facility can accommodate and how many slots the programs that use the facility will need. Finally, the bill would require BRN to place the annual report on its website.

California State Auditor's Assessment of 1-Year Status: Legislation Introduced

Description of Legislative Action

As of January 7, 2021, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 6-Month Status: No Action Taken

Description of Legislative Action

As of September 5, 2020, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 60-Day Status: No Action Taken

All Recommendations in 2019-120

Agency responses received are posted verbatim.