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BRN staff outline travel, testing and international-travel options for probationers and intervention participants

2489870 · March 4, 2025
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Summary

Board staff described how testing and travel requests are handled for probation and intervention program participants, including that Vault (contracted testing) offers many California sites, saliva/oral-fluid testing is used for intervention and is being evaluated for probation, and international travel raises additional legal/process questions.

Board staff outlined how the Board of Registered Nursing handles travel and testing requirements for licensees on probation or in the voluntary intervention program during a Feb. 26 information item.

Deputy Chief Tim Munger and enforcement staff said the board’s vendors coordinate testing site availability when a participant travels. Vault — the contracted specimen-collection network used by BRN programs — operates hundreds of collection sites in California, the board said, and the new vendor Premier is working with Vault to add more locations. Staff said Vault’s mapping sometimes uses ZIP‑code centering that can understate actual travel time in rural areas.

Intervention participants already may receive saliva/oral-fluid testing as part of a range of collection modalities used by the intervention program; staff said oral-fluid testing requires additional safeguards (DNA confirmation on samples, security of chain of custody) to prevent tampering. Probation cases are currently being examined to see whether oral-fluid / saliva collection can be implemented for monitored probation testing: staff reviewed contracts and said saliva testing is a permitted modality for some monitoring but that the board and its vendor must ensure collection security and verification mechanisms.

The board discussed international travel. Staff said international absences raise additional questions such as whether testing obligations should be tolled while a participant is outside U.S. jurisdiction and how monitoring should resume on return. Staff said probation and intervention differ: probation includes statutory rules for tolling and notification, while the voluntary intervention program does not have the same formal tolling mechanism and is handled case‑by‑case.

Staff emphasized a case-by-case approach, balancing participant mobility against the need to prevent travel from being used to avoid testing and compliance. The board did not adopt a new rule at the meeting; staff said they will continue vendor negotiations and report back to the board as Premier expands Vault’s access and as the feasibility of saliva testing for probation is determined.