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December 4, 2003

Barbara Zittel
Executive Secretary to the New York State Board of Nursing
New York State Board for Nursing
The State Education Department/The University of the State of
New York
89 Washington Avenue, 2nd Floor, West Wing
Albany, New York  12234-1000

Dear Ms. Zittel:

The American Association of Community Colleges (AACC), which represents the nation’s 1,173 accredited community colleges, is extremely concerned about a recent proposal to require all registered nurses (RNs) practicing in New York to obtain a bachelor’s degree in nursing within 10 years of entering nursing practice.  AACC strongly agrees with the New York State Board of Nursing’s assertion that “Nurses prepared at the Associate Degree level are the backbone of nursing care in hospitals and nursing homes.”  For more than 50 years, associate degree RNs have practiced nursing alongside their counterparts from bachelor’s schools of nursing, proving to be professionals valued by health care providers and patients.  RNs graduating from associate degree programs pass the NCLEX-RN at the same rate as do four-year graduates; all RNs share the same scope of practice. 

At a time when the nursing shortage is becoming more acute, attacking the majority of front-line nurses in our hospitals and the institutions that educate them is a short-sighted strategy that imperils or undermines the health care of our citizenry. AACC has reviewed each bulleted item in the Board’s letter to Council of Chairs of NYS Registered Associate Degree Nursing Programs and urges the Board to consider our comments in the attached document.

If implemented, AACC believes that the Board’s proposal would negatively impact currently licensed RNs who practice under the authority of the associate degree in nursing, possibly causing them to leave the profession, by creating a two-tiered RN workforce.  In addition, the proposal would increase both the time and costs of nursing education, discouraging students from choosing nursing as a profession.  Furthermore, New York residents may chose to leave the state to pursue nursing education and practice as North Dakota recently learned. (North Dakota—the only state in the nation requiring a bachelor’s degree to practice as an RN—recently overturned this requirement after more than 200 students left the state in 2002-03 to study nursing in associate degree programs in Minnesota.) 
 
America’s community colleges have made a long-term commitment to quality, affordable nurse education and to the delivery of safe health care to the American public.  ADN programs are the most efficient and cost-effective means of addressing the nationwide RN shortage—preliminary 2001–02 data show that the annual resident tuition and fees for students in community colleges was $1,379 compared with $3,746 for students in public four-year institutions.

AACC urges the Board to table the proposal to require RNs to obtain a bachelor’s degree in nursing.  As nursing programs nationwide grapple with unmet enrollment demands and a growing faculty shortage, AACC encourages the Board to consider how it might facilitate creating bridges between New York’s associate degree and graduate nursing (RN to MSN) programs that enroll ADNs.  These 13 graduate programs are an untapped resource in addressing New York’s nursing faculty shortage, and, unlike bachelor’s degree nursing programs, they would advance ADNs to a higher level of education that would expand their roles and responsibilities in the nursing profession as well as enable them to teach.

Thank you for your consideration.  Please direct questions or comments to Roxanne Fulcher, director of Health Professions Policy, AACC, at RFulcher@aacc.nche.edu or 202-728-0200, ext. 274.

Yours truly,

George R. Boggs

CC:  Commissioner of Education, New York State Education Department
 Board of Regents, New York State Education Department

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