Administrative Standards for Health Profession Student Clinical Training
The Oregon legislature passed Senate Bill 879 in 2011, which required the Oregon Health Authority to “convene a work group to develop standards for administrative requirements for student placement in clinical training settings in Oregon.” The intention of SB 879 was: to mitigate inconsistencies that currently exist across clinical placements; to promote efficient solutions to reduce costs for students, health profession programs and clinical placement sites; and to ensure patient, clinical staff and student safety.
More than 80 stakeholders, representing public and private health systems, small and large educational institutions and health profession programs, professional associations, state boards, and other interest groups participated in the work group process. On June 30, 2012 the SB 879 workgroup presented its recommendations for administrative standards for health professional students to the Oregon Health Policy Board, which initiated the rule development process. A Rules Advisory Committee was then established to oversee the development of administrative rules.
These rules establish standards for administrative requirements (immunizations, screenings, trainings, and insurance coverage requirements) for health professional student placements in clinical training settings within the state of Oregon. Students studying in a variety of health profession programs, such as medicine, nursing, pharmacy, professional counseling, and medical assisting, will need to meet these requirements prior to clinical training. For most students, satisfying these requirements once will be sufficient for all subsequent clinical training experiences. Clinical facilities that must abide by these rules include hospitals, health systems, and long-term care residential facilities, as well as others listed in the rules. There are also some exceptions to the rules, including procedures for temporary variations and exemptions for some health profession programs that do not conduct off-site clinical training.
Keeping the Standards Current
These rules will be reviewed annually by OHA and an advisory group that may include representatives of affected students, health profession programs, clinical settings, and healthcare boards that regulate health profession programs. Affected parties may bring proposed changes to the annual review process, and all interested parties will be notified in advance. Any requirements that involve standards regulated by a state or federal regulatory authority (e.g., immunizations, state and nationwide criminal background check) will be updated as needed to remain in compliance.
These rules (OAR 409-030-0100 to 409-030-0250) go into effect on July 1, 2014.
See this Table for a summary list of the administrative requirements that will apply as of July 2014.
|What is the purpose of these rules? |
These rules (OAR 409-030-0100 to 409-030-0250) establish standards for administrative requirements for health professional student placements in clinical training settings within the state of Oregon. The purpose of these rules is to mitigate inconsistencies that currently exist across clinical placements; to promote efficient solutions to reduce costs for students, health profession programs and clinical placement sites; and to ensure patient, clinical staff and student safety.
|Why were these rules created?|
The Oregon legislature passed Senate Bill 879 in 2011, which required the Oregon Health Authority (OHA) to “convene a work group to develop standards for administrative requirements for student placement in clinical training settings in Oregon.” More than 80 stakeholders, representing public and private health systems, small and large educational institutions, professional associations, state boards, and other interest groups participated in the work group process. On June 30, 2012 the SB 879 workgroup presented its recommendations for administrative standards for health professional students to the Oregon Health Policy Board, which initiated the rule development process.
|Who was involved in the rule writing process? |
A Rules Advisory Committee (RAC) was convened to oversee the writing and development of the rules in alignment with the SB 879 workgroup recommendations. The RAC included representatives from educational institutions, clinical sites (e.g., hospitals, health systems), and other stakeholders (e.g., Oregon Health Care Association) and was staffed by individuals from OHA’s Office for Oregon Health Policy and Research.
|How often will these rules be updated? |
These rules will be reviewed annually by OHA and an advisory group that may include representatives of affected students, health profession programs, clinical settings, and healthcare boards that regulate health profession programs Affected parties may bring proposed changes to the annual review process, and all interested parties will be notified in advance. Any requirements that involve standards regulated by a state or federal regulatory authority (e.g., immunizations, state and nationwide criminal background check) will be updated as needed to remain in compliance.
|What are the basic requirements of these rules? |
Students who are required to follow these rules will need to (1) provide evidence of immunization or screening for specific, designated diseases; (2) take a drug test; (3) undergo a state and nationwide criminal background check; (4) complete a variety of basic health professional trainings; (5) provide proof of general and professional liability insurance (usually provided by the health professional program).
|Why are these requirements more/less strict than the ones that some students currently must complete for their clinical training experiences? |
These rules were developed to be the universal standard for all students in health professional programs who are undergoing clinical training in Oregon. The Rules Advisory Committee and the workgroup took into account current requirements for students in a variety of schools and clinical placement settings across the state. Costs, patient and worker safety, convenience, and generally accepted practice requirements (e.g., CPR certification) were all considered prior to making the final proposed rule.
|Can the background check be completed through the Oregon State Background Check Unit (BCU)? |
The BCU will only be completing background checks for (1) students enrolled in a Board of Nursing approved nursing assistant training program in which the instruction and training occurs solely in a nursing facility and (2) A student or intern who provides care or has access to clients, client information, or client funds within or on behalf of any facilities licensed or certified by the Department to provide services for individuals with developmental disabilities, or by the Authority’s Addictions and Mental Health Division to provide mental health services. BCU rules: http://arcweb.sos.state.or.us/pages/rules/oars_400/oar_407/407_007.html.
|Which students do these rules impact? |
These rules apply to post-secondary students who are studying in an included/listed health professional discipline, and who are completing clinical training experiences in a facility outside of their health profession program. For example, some of the listed fields of study include: dentists, physicians, medical assistants, nurses, pharmacists, and professional counselors.
|Do these rules apply to students who go to school outside of Oregon but plan to do some or all of their clinical training in Oregon?|
Yes. Any student in the listed health professions who does clinical training in the state of Oregon is required to meet these standards after July 1, 2014.
|Do these rules apply to students who are studying in a field or profession that isn’t listed in OAR 409-030-0130 “Health Professional Disciplines”? |
No. Students studying in non-listed professions (e.g., acupuncture, chiropractic, massage therapy, esthetics, etc.) are not required to meet these requirements. However, a clinical site may choose to have all students regardless of discipline follow these rules as a condition of training at that site.
|Do these rules apply to instructors who accompany students on-site during their clinical training (e.g., nursing students are often accompanied by an on-site clinical instructor from their program)? |
It is up to the clinical site to determine if it will require instructors from the health profession program to abide by these rules. However, the clinical site cannot require instructors to meet requirements that are above and beyond those listed in the rules (e.g., additional immunizations or a more extensive background check).
|How often must instructors renew or go through the requirements process again? |
If the clinical site requires instructors to abide by these rules, it is recommended that clinical sites do not require instructors to renew or go through a portion of or the entire requirements process repeatedly unless: it is for cause; the instructor has changed places of employment or has had an extended leave of absence; the instructor holds a license from a state board that requires regular updates to maintain the license; or there has been a change from a state or federal regulatory agency that oversees a portion of these rules and has updated its requirements.
|Are there any facilities that are automatically exempted from these rules?|
Yes. A number of facilities have requirements that are set at the federal level (e.g., Department of Veterans’ Affairs facilities) or are otherwise separately developed (e.g., state prisons and correctional facilities). Students wishing to do a clinical rotation at those sites will need to meet the administrative requirements set forth by those facilities.
|Can other clinical training sites receive exemption from these rules?|
Potentially. Clinical sites that have fewer or less stringent administrative requirements for newly hired non‐student employees may request exemption from specific provisions of OAR 409‐030‐0170 through OAR 409‐030‐0240 for students performing clinical placements at that site.
For example, a clinical placement site that does not require new employees to take a drug screen prior to being hired may request exemption from the section of these rules that require students to take a drug screen prior to being placed at that clinical site. All other requirements listed in the rules, except for the drug screen, would still be required. Specific instructions for requesting exemption are listed in the rules.
|If a student meets the requirements listed in the rules, is that student automatically provided with a clinical placement (or internship, residency, etc.) at a listed clinical site? |
No. Completion of the administrative requirements only ensures administrative clearance for students. Clinical placement sites still make all final clearance and placement decisions based on specific criteria that may be unique to each facility.
|Do students need to meet all the requirements in these rules prior to participating in clinical training, observations, labs, or other types of clinical experiences that are conducted on-site at their educational facilities? |
No. These rules are not intended for students who undergo clinical training on-site (e.g., an on-site dental clinic at a dental school), where students train under the supervision of the educational facility. However, those students must abide by these rules prior to any off-site clinical training experiences.
|What is an “acceptable” vs. “unacceptable” background check or drug screen?|
These rules do not outline or define what constitutes an “acceptable” (or not) drug screen or background check. Instead, the rules simply outline the type of drug screen and background check that must be completed. The clinical site, often in conjunction with the health profession program, will always make all final placement decisions for students interested in training at the clinical facility.
For more information, please contact:
Stephanie Jarem, Policy Analyst, email@example.com or 971-273-6844.