Scope and Methodology
The Joint Legislative Audit Committee (Audit Committee) directed the State Auditor to examine BRN’s oversight of nursing programs. Specifically, we reviewed BRN’s process for approving new nursing programs or programs seeking to expand and its efforts to analyze the nursing workforce in California. The Table lists the objectives that the Audit Committee approved and the methods we used to address them.
|Review and evaluate the laws, rules, and regulations significant to the audit objectives.
|Reviewed relevant laws, rules, and regulations.
|Determine whether BRN is appropriately reviewing and approving nursing programs, including the following:
a. Whether BRN’s policies and procedures for approving, denying, deferring, or revoking its approval of nursing programs comply with laws and regulations.
b. Whether the factors that BRN uses when considering a request from a school to expand its nursing program are reasonable.
c. Whether BRN consistently and objectively applied these factors as a part of its decision-making process for a selection of requests.
|Review petitions of regulatory violations related to nursing programs filed against BRN with OAL over the last three years and summarize the outcomes of the complaint process.
|Obtained and reviewed OAL’s list of petitions for regulatory violations regarding BRN and summarized outcomes.
|Determine whether there are adequate conflict-of-interest rules or policies for governing board members, executive management, and nursing education staff who work on the oversight of nursing programs. Further, to the extent possible, identify whether BRN’s staff or governing board members appropriately recused themselves from decisions regarding nursing programs with which they may have had a conflict of interest.
|Identify the process BRN uses to evaluate clinical displacement and whether it consistently and objectively uses that process across all nursing programs. For a selection of requests for increased enrollment or new nursing programs, assess the factors BRN evaluated in making its decisions and the resulting clinical displacement.
|Determine whether BRN’s oversight of nursing programs is appropriate, including the following:
a. Whether BRN is duplicating oversight of nursing programs conducted by other entities, including state and federal entities, as well as nursing school accreditors.
b. An assessment of the expertise BRN relies on when it evaluates the curricula of nursing programs.
|Determine whether BRN’s analysis of California’s nursing workforce is reasonable and consistent with the scope and breadth of current and future health care workforce needs as identified by similar analyses.
|To the extent possible, identify the time spent and resources used by BRN on each of its programs.
|Review and assess any other issues that are significant to the audit.
Source: Analysis of the Audit Committee’s audit request number 2019-120, and information and documentation identified in the column titled Method.
Assessment of Data Reliability
In performing this audit, we relied on electronic data files that we obtained from OAL related to petitions it received and from OSHPD’s website related to health care facilities. The U.S. Government Accountability Office, whose standards we are statutorily obligated to follow, requires us to assess the sufficiency and appropriateness of computer‑processed information we use to support our findings, conclusions, and recommendations. We used the data from OAL to verify that it had received two petitions related to BRN over the last three years. OAL performed for us multiple queries of its system to identify petitions related to BRN, and each query identified the same two petitions; therefore, we determined that the data were sufficiently reliable for our purpose. We also downloaded from OSHPD’s website the list of health care facilities. We used the data to identify clinical facilities that nursing programs are not currently using for clinical placements. We verified that the data included logical information; however, we did not perform completeness testing because the supporting documentation is maintained at the facilities, making such testing impractical. We concluded that the data are of undetermined reliability. Although we recognize that this limitation may affect the precision of the numbers we present, there is sufficient evidence in total to support our audit findings, conclusions, and recommendations.