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Agenda Item #14.B.1c:::lc:::aDEPARTMENT OF CONSUMER AFFAIRSBUSINESS, CONSUMER SERVICES, AND HOUSING AGENCY GOVERNOR EDMUND G. BROWN JR.BOARD OF VOCATIONAL NURSING & PSYCHIATRIC TECHNICIANS2535 Capitol Oaks Drive, Suite 205, Sacramento, CA 95833-2945Phone (916) 263-7800 Fax (916) 263-7855 Web www.bvnpt.ca.govDATE:October 1, 2018TO:Board MembersFROM:Jessica Gomez M.S.N., R.N.Nursing Education ConsultantSUBJECT:Integrity College of Health Vocational Nursing Program –Consideration ofProvisional Approval (Director: Melody Cochran, Pasadena, Los Angeles County,Private).STAFF SUMMARY:On June 5, 2018, Integrity College of Health Vocational Nursing Program requestedapproval to admit a class of 20 students on July 24, 2018. On July 3, 2018, that requestwas denied due to lack of resources, specifically adequate faculty and facilities for therequested classes.It was determined that Board staff would conduct an onsite inspection. The announcedonsite inspection was conducted August 2 and 3, 2018. Three violations related toinadequate resources were identified.On August 10, 2018, the program was sent a notice of violation via certified mail. Theprogram was instructed to respond to the notice no later than August 24, 2018. A oneweek extension was given to the program, however, to date the program has not providedthe requested response.On September 5, 2018 the Board received two complaints that an instructor who is notBoard approved has been teaching courses within the VN program.On September 10, 2018, the program owner called and stated that while she was out sickher daughter had stepped in to manage the program. Her daughter with the best intentionshad taught a course within the VN program.On October 1, 2018, the Education committee placed the Integrity College of Health,Vocational Nursing Program on the November 16, 2018, Board Agenda forconsideration of placement on provisional approval.

Agenda Item #14.B.1STAFF RECOMMENDATIONS:1. Place Integrity College of Health, Vocational Nursing Program on provisionalapproval for a two-year period beginning November 16, 2018, and direct staff toissue a certificate accordingly.2. Require the program to provide documentation verifying, under the penalty ofperjury that all currently enrolled students scheduled to graduate in October andNovember of 2018, have completed all required clinical experience in Pediatricsand OB.3. The documentation must be submitted prior to the submission of the studentsrecord of completion of the program to the Board for processing.4.Require the program to admit no additional classes without prior approval by theBoard.5.Require the director to submit follow-up reports in 10 months, but no later thanSeptember 1, 2019, and in 22 months but no later than September 1, 2020. Thereport must include a comprehensive analysis of the program, specific actionstaken with revisions to improve pass rates, timeline for implementation, and theeffect of employed interventions. The following elements must be addressed in theanalysis:a. Admission and Screening Criteriab. Terminal Objectivesc. Evaluate the Current Curriculum for Possible Update Curriculum to include:1- Program objectives2- Instructional Plan3- Theory and Clinical Objectives for Each Course4- Lesson Plans for Each Course5- Evaluation of Correlation of Theory and Clinical6- Textbooksd. Student Policies to include1- Attendance Policy2- Remediation Policy3- Evaluation of Student Achievement4- Credit Grantinge. Evaluation of available clinical facilities approvals to determine adequacyin number and variety to accommodate current and projected students.6.Continue the program’s requirement to comply with all approval standards inArticle 4 of the Vocational Nursing Practice Act, commencing at Business andProfessions Code Section 2880, and Article 5 of the California Code ofRegulations, Title 16 commencing at Section 2526.7.Failure to take any of these corrective actions may cause the full Board to revokethe program’s approval.2

Agenda Item #14.B.1History of Prior Board Actions(See Attachment A)EnrollmentThe program offers a full-time course of instruction that is 60 weeks in length. Approvalby the Board is required prior to admission of each class. The pattern of admissions forcurrent and proposed classes in seen in the enrollment table below.The following table represents student enrollment based on current class starts andcompletions. The table indicates a maximum enrollment of 47 students for the periodfrom July 2017 to April 2018.ENROLLMENT DATACLASS 8*6/19#StudentsAdmitted#StudentsCurrent orCompletedTotalEnrolled2199 1616516 5 21151521 15 36201136 11 47*Expected date of graduationLicensing Examination StatisticsThe following statistics, furnished by Pearson Vue and published by the National Councilof State Boards of Nursing as “Jurisdictional Summary of All First-Time CandidatesEducated in Member Board Jurisdiction” for the period July 2016 through June 2018specify the pass percentage rates for graduates of the Integrity College of HealthVocational Nursing Program on the National Council Licensure Examination forPractical/Vocational Nurses (NCLEX-PN ), and the variance from state average annualpass rates.3

Agenda Item #14.B.1QuarterJul – Sep 2016Oct – Dec 2016Jan – Mar 2017Apr – Jun 2017Jul – Sep 2017Oct – Dec 2017Jan – Mar 2 018Apr – Jun 2018Jul - Sep 2018NCLEX-PN Licensure Examination DataQuarterly StatisticsAnnual Statistics*##%StateProgramStateVarianceCandidates Passed Passed AverageAverageAveragefrom StateQuarterlyAnnualAnnualAveragePass Rate Pass RatePass RateAnnual[CCR §2530(l)] Pass 73%-610770%68%76%74% 233100%74%78%71% 74375%69%78%71% 76583%81%78%73% 510770%79%78%76% 25771%77%74%76%-2*The Annual Pass Rate changes every quarter. It is calculated by dividing the number of candidates who passed duringthe current and previous three-quarters by the number of candidates who tested during the same period. If no data isavailable for the relevant period, the statistic is carried over from the last quarter for which data is available.California Code of Regulations section 2530(l) states:“The program shall maintain a yearly average minimum pass rate on thelicensure examination that does not fall below 10 percentage points of thestate average pass rate for first time candidates of approved vocationalnursing schools for the same period.”Based on the most recent data available (July - September 2018), the program’s averageannual pass rate is 74%. The California average annual pass rate for graduates fromapproved vocational nursing programs who took the NCLEX-PN for the first time duringthe same period was 76%, two percentage points below the state.Faculty and FacilitiesSection 2534(d) of the Vocational Nursing Rules and Regulations states:"For supervision of clinical experience, there shall be a maximum of 15 studentsfor each instructor."The number of Board-approved faculty is 11, including the director. The director has bothadministrative and teaching responsibilities. Eleven instructors including the director aredesignated to teach in the clinical area.For a maximum enrollment of 47 students, four instructors are needed. Therefore, thenumber of faculty is sufficient for the current and proposed enrollment, however, basedon evaluation of submitted documents and findings during the on-site program inspection;the utilization of faculty at clinical facilities is such that clinical instruction is not coveredadequately.4

Agenda Item #14.B.1Section 2534(b) of the Vocational Nursing Rules and Regulations states:“Schools shall have clinical facilities adequate as to number, type, and variety ofpatients treated, to provide clinical experience for all students in the areas specifiedby Section 2533. There must be available for student assignment, an adequate dailycensus of patients to afford a variety of clinical experiences consistent withcompetency-based objectives and theory being taught.”Based on analysis of documents submitted by the director, documents viewed during thesite inspection and interviews of students, faculty and the program director it was verifiedthat the program does not have sufficient clinical facilities to afford the number, type,and variety of patients that will provide clinical experiences consistent with competencybased objectives and the theory being taught for the enrolled student population.Data Related to Consideration of Placement on Provisional ApprovalOn July 3, 2018, the Executive Officer denied the program’s request to admit a class of 20students due to the lack of adequate clinical facilities for the instruction of pediatric andmaternal nursing.On July 18, 2018, the Board was notified by a program administrator, that the currentprogram director had been ill and unable to actively administer the program. Theadministrator was administering the program in the director’s absence. The administratorwas instructed that the program must have a Board approved program director directlyresponsible for the active administration of the program.On July 20, 2018, the Board approved a new program directorOn August 2 and 3, 2018, two Board staff conducted an announced program visit. Thevisit had been scheduled as an unannounced program inspection, however, due to thenewly appointed program director it was determined that the visit would be announced.During interviews of students, faculty, program staff, and the program director, as well asinspection of program documents, it was identified that:1. The current cohorts of term two and three students scheduled to graduate inOctober and November 2018 did not receive clinical placements for pediatric andmaternity nursing experience during term two as required by the Board-approvedinstructional plan.2. The only clinical sites currently available to the program for pediatrics experiencewere day care centers which are not approved for the care of the sick child asrequired by statute.3. The OB physician who accepts students for clinical experience at his clinic, hadbeen out of town on vacation for several months and, at the time of the programvisit, had not returned to his practice.5