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.

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.

  • Estimated Completion Date: July 2021
  • Response Date: September 2020

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.

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.

  • Estimated Completion Date: January 2021
  • Response Date: September 2020

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.

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.

  • Estimated Completion Date: January 2021
  • Response Date: September 2020

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.

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.

  • Estimated Completion Date: January 2021
  • Response Date: September 2020

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.

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.

  • Estimated Completion Date: April 2021
  • Response Date: September 2020

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.

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.

  • Estimated Completion Date: April 2021
  • Response Date: September 2020

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.

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.

  • Estimated Completion Date: April 2021
  • Response Date: September 2020

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.

  • Completion Date: August 2020
  • Response Date: September 2020

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.

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.

  • Estimated Completion Date: October 2021
  • Response Date: September 2020

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

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

  • Legislative Action Current As-of: September 2020

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

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

  • Legislative Action Current As-of: September 2020

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

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

  • Legislative Action Current As-of: September 2020

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

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

  • Legislative Action Current As-of: September 2020

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


All Recommendations in 2019-120

Agency responses received are posted verbatim.