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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 district. 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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