PSEA DIABETIC TALKING POINTS
                                   April 2009

The PSEA School Nurse Section Executive Board representing approximately 1400
Certified School Nurses in the Commonwealth strongly supports optimal health care for
the nearly 2 million school children, including those with disabilities such as Diabetes.

Historically, Certified School Nurses have championed the cause of all students with
disabilities and have advocated for the highest quality of health care that is
comprehensive, multidisciplinary, family-centered, easily accessible and culturally
competent. It is our desire that every student reach his or her full academic potential
through maintaining the optimal level of wellness. This is a long-term approach for a
healthy, strong democracy. It is upon this premise that we offer comment on HB 1113.

One can recognize that the intent is to safeguard the rights and well being of the student
with diabetes. It appears that HB 1113 might be a template bill designed on the national
level to be implemented in every state. However, the School Health Services in
Pennsylvania are unique and do not articulate well with this proposed piece of legislation.
Although well-intentioned, HB 1113 falls short in accomplishing this goal.

      To delegate the complex case management of a medically fragile student to non-
       medical unlicensed personnel is a high-risk situation for the student, the
       designated school employee, the assigned Certified School Nurse, and the school
      The bill allows for the administration of medication by unlicensed personnel in
       direct violation of the Nurse Practice Act.
      The statutory responsibility for the care of the student rests with the Certified
       School Nurse who does not have the commensurate authority to hire, supervise, or
       delegate responsibilities to the “trained diabetes personnel” (unlicensed school
       employee) referenced in the bill. The lines of accountability are unclear.
      The bill fails to utilize the expertise of the Certified School Nurse assigned to the
       care of the child with diabetes. According to HB 1113, the student’s family and
       personal health care team would develop the diabetic health care plan. A more
       comprehensive recommendation would be that the health care plan be developed
       in collaboration with all the members of the health team, including the school and
       the Certified School Nurse as part of the team.
      Certified school nurses maintain that students with diabetes should have
       developmentally appropriate access to diabetic supplies and equipment while at
       school. The safety of the child with diabetes as well as the total school
       community must be considered. The bill does not take the developmental level of
       the student or the appropriateness of the school environment into consideration on
       this matter.
      While Certified School Nurses encourage and understand the need for
       independence and self care of the student with diabetes, we believe there still
       remains a necessity for the student to collaborate, to some degree, with the
       certified school nurse regarding their medical status. Without this collaboration,
    if an emergency should arise, the Certified School Nurse responding to the
    emergency will have no knowledge of the student’s recent blood glucose levels
    and the interventions taken by the student.
   Since medical management is fragile, ever changing, and highly individualized, it
    is not prudent to legislate blanket care for children with diabetes on a universal
    basis. As advocates for students, we find that caring of children in school settings
    is serious business and too important to be delegated to non-professional
    employees. Caring for the child with diabetes in school settings demands many
    high level skills other than those detailed in the bill. Required care encompasses,
    but is certainly not limited to, the use of therapeutic communication and education
    techniques, a broad knowledge base of child and adolescent development, and
    understanding of pathology and pathological responses of illness,
    pharmacological background, comprehension of family dynamics, and team
    leadership ability.
   Certified School Nurses believe that HB 1113 attempts to circumvent the
    safeguards of the Nurse Practice Act. Section 1414.3 entitled “Diabetes Medical
    Management Plan,” states that “Functions performed by these (non-health care)
    professionals “shall not constitute the practice of nursing.” We believe that the
    care of the child with diabetes most definitely is within the practice domain and
    art and science of nursing. Also, “under the PA Nurse Practice Act, there is no
    provision for a registered nurse (RN) to delegate nursing tasks, such as assessing
    blood glucose or administering insulin or glucagon to an unlicensed individual”
    (Diabetes in School Children: Recommendations and Resource Guide for
    Pennsylvania School Personnel, 2009, p. 18.) In Section 1414.3 of HB 1113,
    lines 14-16 it states that … “a school nurse shall be the primary provider of
    diabetic care and treatment and responsible for any ‘delegation’ of care. As
    previously stated, delegation of care is in violation of the PA Nurse Practice Act.
    The Standards of Nursing Conduct approved by the PA State Board of Nursing
    provide: [A] licensed nurse shall not assign to unlicensed individuals functions
    which shall be performed only by a licensed nurse…[and]…should not teach
    unlicensed persons to perform…[those functions]. This information cited above
    is supported by a 1978 Attorney General’s Opinion. We stand firm in our belief
    that the current Nurse Practice Act safeguards the health and safety of our citizens
    and should be adhered to as it stands.
   An additional concern remains. This pattern of exempting caregivers from the
    jurisdiction of the Nurse Practice Act will lead to the gradual erosion and dilution
    of the practice and standards for all health care. Will there be individual caregiver
    bills for all other diseases that attempt to circumvent the standards and practice of
    nursing? We want to provide our youth with licensed professional care and
    reverse or, at least, stem the short-sighted, quick fix, cheaper solutions that run
    contrary to the concept of long-term solutions and quality health care.

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