CACN tells BRN to broaden placement definitions, expand simulation use and simplify EDPP-18 to address clinical shortage

Representatives of the California Association of Colleges of Nursing (CACN) outlined a set of recommendations to the Nursing Education and Workforce Advisory Committee on June 25, asking the Board of Registered Nursing to broaden the regulatory language for clinical placements, permit more flexible use of simulation, and streamline the EDPP-18 clinical reporting form to reduce administrative burden.

Who spoke and what they asked CACN immediate-past president Kim Paris and policy chair Dr. Eileen Fry Bowers urged the BRN to consider aligning placement and competency language with accrediting bodies (for example, AACN essentials) so programs can use nontraditional clinical sites (ambulatory care, telehealth, community settings) when they meet learning objectives. CACN also recommended the BRN revisit the fixed direct‑care-hour approach and allow greater, evidence-based use of simulation for scenarios that students might not reliably encounter in clinical placements.

CACN raised other issues under pressure from shortages in clinical sites and faculty: EDPP-18 (the clinical placement form) is administratively burdensome and in some cases health systems have refused to sign; the association urged improvements to the form and suggested data sharing with Health Care Access & Information (HCAI) to eliminate duplicate reporting. CACN also flagged concerns about the rarely used 30-unit (non-degree) pathway to RN licensure — they said the option creates ethical and transferability problems for students who may need a degree for employment at some hospitals.

BRN staff responses and practical clarifications BRN Executive Officer Laurie Melby and NEC staff responded with detailed points intended to clarify how existing regulation can be used: - Telehealth and ambulatory modalities can meet direct‑patient‑care objectives if the program demonstrates how objectives are met. Melby said the BRN has recognized telehealth as an acceptable modality since the COVID period. - The BRN adopted a 500-hour minimum for prelicensure clinical plus simulation; within that total, programs must include at least 30 direct‑care hours in certain areas (pediatrics, OB, psych) so schools have flexibility to shift remaining hours into simulation when placements are scarce. - EDPP-18 has been moved to an online submission system; BRN staff said they corrected language that had previously deterred some facilities from signing (a clause suggesting a guarantee against displacement was removed). - The BRN noted it lacks regulatory authority over clinical facilities (hospitals, clinics) and therefore asks academic programs to demonstrate coordination (consortia, regional planning) when applying for new programs or enrollment increases.

Public comments and stakeholders Deans and directors from several colleges spoke in support of CACN’s concerns. Kim Dunker, dean at Pacific Union College, and Sarah Frey, Director of Nursing at College of the Desert, described acute difficulty recruiting directors and preceptors in rural regions and urged more flexible pathways and institutional support for directors. Several meeting participants recommended mentorship, executive leadership fellowships, or targeted budget/administrative training for prospective directors.

What was decided and next steps No regulation or statute was changed at the meeting. BRN staff said they will take CACN’s letter into account and noted several operational fixes (EDPP-18 online changes, second-look process for NEC denials). CACN asked for a continuing dialogue with BRN staff; MEWAC members and BRN staff suggested follow-up at conferences and workshops to share implementation examples and best practices.

Quotes "We would like a conversation to allow for more simulation in California… simulation allows us to ensure that students are exposed to very specific patient care scenarios," said Dr. Eileen Fry Bowers (CACN policy chair).

"Telehealth is accepted. You just have to show us how it's meeting your objectives," BRN Executive Officer Laurie Melby said.

Ending CACN and BRN staff agreed to continue the discussion and to surface model approaches at future conferences and to MEWAC subcommittees. The BRN invited specific examples of denied clinical approvals so staff and NECs could re-review decisions.