| Sample Letter to BORN
Draft Letter - Multiple Issues
September 22, 1999
Ms. Marie McCarthy
Chair, Board of Registration in Nursing
239 Causeway Street
Boston, Massachusetts 02114
Dear Ms. McCarthy, and Members of the Massachusetts Board
of Registration in Nursing.
My name is Jane Smith and I have been a registered nurse
for 14 years. I primarily practice in medical surgical nursing
in a hospital setting.
I am writing to express my concerns regarding the proposed
regulation at 244 CMR 2.00 and 7.00, the Standards of Conduct
for Nurses and the Disciplinary Actions. As a staff nurse,
I am very concerned about a number of issues and make the
following suggestions for change: "Standards of Nursing Practice"
- this definition does not include the professional standards
that apply to my practice, which are published by the professional
organizations in nursing. I use this daily and I know they
are used in a court of law to evaluate practice, therefore
they must be in the regulation.
(14) Nursing Assessment - the definition you have written
does not include the direct observation by the nurse for which
she/he has "direct patient care responsibility". As written,
I am sure that others such as nurse's aides can be used for
direct observation, and I will simply be relegated to "systematically
collecting and verifying information about a patient" that
others will observe. Please include "observe" in this definition.
This would be clarifying and does not negate the appropriate
use of unlicensed persons, when I chose to delegate a task,
such as taking a blood pressure.
(18) Leaving a Nursing Assignment - is currently threatened
by employers when nurses refuse mandatory overtime. This definition
does not take into account either a contracted or limited
time commitment for patient care nor the potential to report
to any one other than an "appropriate care giver". I may report
to a supervisor who will then secure another caregiver. Please
alter this language to make it very clear that "leaving a
nursing assignment" is the inappropriate and purposeful severance
of the nurse patient relationship, not going home at the end
of a shift or refusing mandatory overtime.
(52) Responsibilities of Nurse in the Management Role - I
am concerned that their responsibilities do not include the
certainty that the nursing care staff is competent for the
patient assignment. The definition only notes they must be
accountable for competence for "the job". When "floated" to
another unit, I am held accountable to be competent for all
patient care, but if I am "floated to a dialysis unit" I would
not have the skill set and knowledge, yet the job is the same,
that of a registered nurse. Please change this language to
reflect the need to assure competence for the patient assignment.
Lastly, I am very concerned about the lack of clarity in
the regulation to assure due process protections in relation
to summary suspension. I agree with the recommendations proposed
by the MNA.
Thank you for recording my written testimony,
Sincerely,
Jane Smith, RN
100 Main Street
Anytown, Massachusetts 02027
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