Student Clinical Compliance

Policy Subject: Student Success

Policy: Student Clinical Compliance

Revised: December 2020

Effective date: December 2020

Review date: 2023

Responsible Party: Level 1 UAAC & GAAC; Level II: Associate Dean for Academic Affairs

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Introduction and Purpose

To promote patient safety, decrease institutional liability, and comply with clinical placement contracts, the College of Nursing requires students to adhere to CDC immunization recommendations relevant to health-care workers, demonstrate a negative urine substance screen test at application and annually to permit students in the clinical setting, and meet agency background check policies.

Policy

1. Undergraduate and graduate nursing students must verify they have met the initial and annual College of Nursing clinical compliance requirements for immunizations, preventive practices, background checks and urine substance screening. Clinical compliance tracking is done at the student’s expense.
2. Students who have not completed the clinical compliance requirements and submitted the documented evidence in the clinical compliance tracking system by posted deadlines or for whom the required screens reveal prohibited behavior in their documentation, background check, or urine drug screen will not be allowed access to clinical agencies or any related clinical activities including simulation and skills labs. Noncompliance may result in dismissal from the College of Nursing. Decisions may be appealed to the College of Nursing Scholastic Committee.
3. Background Checks:
   1. Applicants with prohibited behavior or self-reported disclosures on their background checks will be evaluated individually by the Associate Dean for Academic Affairs, in consultation with the Dean, to determine admission to the respective degree program.
   2. Currently enrolled students with prohibited behavior or self-reported disclosures on their background check will be evaluated individually by the Associate Dean for Academic Affairs, in consultation with the Dean, to determine whether they will be allowed continued progression in the respective degree program. For undergraduate students, the respective campus director will also be consulted.
   3. If the student has been convicted of a violation of the law and it is not reported on the background check, it may be grounds for dismissal from the College of Nursing. The student has the responsibility to self-report past violations and any subsequent violations while enrolled to the Associate Dean for Academic Affairs for review. 

4. Substance Screening*:
   1. Students are not allowed to attend clinical or lab settings if impaired. No student shall report for or remain at a clinical or lab setting while under the influence of any substance that could impair the ability of the student to safely perform the functions of the assignment. This applies both to illegal substances and the lawful use of over the counter or prescribed medications that may impair their ability to function safely in the clinical environment and thereby endanger patients and self. As such, all students are responsible for being aware of the effect these medications may have on their ability to function safely in the clinical practicum. Students must notify the Campus Director regarding the use of any medication that can impair performance for review prior to entering the clinical environment.
   2. Students cannot participate in clinical education if they are taking any medications that impair their ability to function safely in the clinical environment, regardless of the presence of a legally obtained medical cannabis document.
   3. The College of Nursing may test for substances, (alcohol or drugs) for reasonable suspicion of being under the influence in the classroom/clinical setting and after an accident or incident in the classroom, lab, simulation or clinical setting.
   4. *On November 3, 2020, Montana voters passed Initiative 190 and Constitutional Amendment 118, which allows for limited recreational use of marijuana for adults age 21 and older. However, use or possession of marijuana remains a federal crime.  Per the Montana Board of Regents, the possession or use of marijuana on campus property and in MUS programs is prohibited. The MSU Code of Student Conduct described this policy in more detail including that all forms of marijuana are prohibited including tinctures, edibles and topicals. Students who use or possess marijuana on campus are subject to discipline.

       In addition, as a nursing student -- and when you become a nurse -- you are obligated to meet the clinical compliance requirements of a clinical agency. These requirements include a negative urine drug test when you apply to nursing school and annually while in the program.  Per CON policy, applicants or current students with a positive urine drug test are not allowed in the program.  Applicants may re-apply in the next admission cycle with permission of the CON Scholastic Committee.  Current undergraduate or graduate nursing students may seek reinstatement through the CON Scholastic Committee. 

5. Immunizations:
   1. Immunization requirements are based upon current CDC guidelines for healthcare providers.
   2. Students who cannot meet the listed immunization and TB screening requirements for health-related reasons must provide and upload documentation with rationale from their health care provider to their clinical compliance management account. This will be reviewed by the Associate Dean for Academic Affairs, or designee, in advance of any clinical coursework placement.
6. Annual Clinical Training (e-Learning):
   1. Students will complete annual clinical education related to HIPAA, OSHA, Standard Precautions, and TB Prevention.
   2. Individual clinical agencies may have additional onboarding requirements.
7. CPR: Students must maintain current CPR certification for Health Care Providers while enrolled in the program. This certification must cover all ages, infant through adult and the use of AED. The College of Nursing only accepts certification through the American Heart Association.

 Procedures

1. Students will be informed through the application process on the following clinical compliance requirements used for admission and throughout enrollment in the nursing program.
2. The initial compliance documentation must be completed prior to the first semester of courses.
   1. The College of Nursing utilizes a clinical compliance tracking system for all Urine Drug Screens, background checks, immunization tracking, CPR verification, and E-learning compliance Graduate students will provide a copy of RN licensure. 
   2. Students must create a compliance tracking account as part of the application process.
   3. Urine Drug Screens, background checks, must be completed at application CPR verification, and E-learning must be completed prior to the start of nursing courses.   
   4. Status of all immunizations must be uploaded by the admission except:
      1. Hepatitis B may be in process
      2. TB step 2 may be in process
   5. Annually thereafter, and by August 25^th for Accelerated BSN students, a urine drug test, background check, and e-learning must be completed along with immunization updates (see table below).

**BEGINNING SPRING 2021:  All new applicants will transition to Complio for Clinical Compliance Tracking. 

3. Test Results, Ongoing Monitoring, and Readmission
   1. Negative Substance Screen: Students and applicants whose urine drug screen results show a negative substance screen (i.e., no substances detected) are eligible to begin and continue coursework.
   2. Negative Dilute, Adulterated or Other Inconclusive Substance Screen: Students and applicants whose results show a negative dilute, adulterated or other outcome that is neither positive nor negative must take a second urine substance screen at the same site within 24 hours of notice of the results or as soon as possible. Two separate negative dilute, adulterated or other inconclusive outcome will be treated in the same manner as a positive drug test. Students should avoid overhydrating which may result in a dilute sample.
   3. Positive Substance Screen: A positive substance screen will be confirmed by the Medical Review Officer (MRO) from the clinical compliance tracking system approved drug testing laboratory.
4. Undergraduate and graduate students with a positive substance screen, or whose results are treated as a positive substance screen, will meet with the Campus Director for undergraduate students on the campus where the students is located and the Associate Dean for Academic Affairs to review the testing results and the College of Nursing policy. Graduate students will meet with the Associate Dean for Academic Affairs to review the testing results and the College of Nursing.

1. 1. Undergraduate and Graduate students with a positive drug screen confirmed by a MRO, or whose results are treated as a positive drug screen, will be removed from the program of This decision may be appealed to the CON Scholastic Committee.
   2. Reinstatement Undergraduate: Undergraduate students with a positive substance screen or whose results are treated as a positive substance screen, will be requested to see a licensed addiction counselor for assessment and evaluation and possible participation in monitoring if indicated by the evaluation. Any student seeking reinstatement through the Scholastic Committee, will need to show proof of the evaluation, and if determined necessary by the licensed addiction counselor, subsequent monitoring which may include random urine drug screens. Monitoring may be required while enrolled in the traditional or accelerated BSN program and may include reporting to the Associate Dean or random urine drug testing. Traditional and ABSN undergraduate students are subject to semester by semester placement policy.
   3. Reinstatement Graduate: Any graduate or Associate Degree RN to MN student seeking reinstatement through the Scholastic Committee for a positive substance will be required to utilize the Montana Professional Assistive Program (MPAP) and must show evidence of this to the Scholastic Committee. If MPAP evaluation has indicated a need for monitoring and counseling, reporting of participation to the Associate Dean may be Random urine drug screens may be requested while enrolled in the program. 

5. Applicants with a positive UDS will not be admitted to the program and may apply in the next admission cycle. Applicants (students seeking placement and who have a positive UDS history in a previous application cycle ) will be required to show evidence of a substance abuse screening/evaluation from a licensed addiction counselor and if required by the screening, follow-up counseling and random urine drug. 

      6.  Reasonable Suspicion Testing 

1. 1. Undergraduate and graduate students may be required to submit to reasonable suspicion testing as stipulated in the drug testing policy of the College and/or clinical agency while participating in class, lab, simulation or clinical experiences. MSU student code of conduct 625.00 prohibits use, possession, or distribution of intoxicants, including alcohol on the buildings or grounds of MSU. If a student is involved in a course-related accident or course-related incident involving safety or patient care, the student may also be subject to reasonable suspicion testing.
   2. Reasonable suspicion may be based on but not limited to observable phenomena such as direct observation of substance abuse and/or the physical symptoms or manifestations of substance abuse such as:

• • • Speech – incoherent, confused, rapid, slow, slurred, rambling, shouting, profanity, or change in speech.
    • Coordination – swaying, staggering, lack of coordination, grasping for support, slowed reflexes.
    • Demeanor- change in personality, excited, combative, agitated, aggressive, violent, argumentative, indifferent, threatening, antagonistic, mood swings, irritability, restlessness.
    • Alertness – change in alertness, sleepiness, drowsiness, confused.
    • Physical – bloodshot eyes, teeth grinding, nasal redness, dry mouth, flushed face, tremors, pupillary changes, odor of substance and/or alcohol.
    • Appearance- dirty clothing, disheveled.
    • Performance – unsafe practice, unsatisfactory work, absenteeism, tardiness.
    • Evidence of involvement in the use, possession, sale, solicitation or transfer of drugs.

       7. If a faculty member or clinical agency staff member observes behaviors listed above, the student will be                     removed from the educational setting and the Campus Director, or a designee, will be notified immediately.

       8. The Campus Director, or designee, will decide if drug/alcohol testing is warranted. If the decision is made to              test the student, arrangements will be made to have the testing done immediately.

9. Students must use and follow the procedures of the drug testing laboratory recommended and approved by clinical compliance tracking system. If immediate alcohol testing is needed, arrangements will be made with a local clinical agency at the student’s expense.
10. The student must access their clinical compliance tracking account and place an order for a single urine drug test at the current location (zip code). This will generate an order in the student’s account to be printed and taken to the approved testing site. The student will be responsible for the cost of the testing.
11. Students are not to drive themselves for testing nor should they be driven by faculty or faculty’s designee. Transportation should occur using a cab service. Transportation costs are to be incurred by the student.
12. If student refuses testing, arrangements for travel home should still be made.
13. If the results of the drug/alcohol screen are positive, the student will be withdrawn from all nursing courses.
14. If the student refuses or fails to submit to the substance screen, it will be treated as a positive test and the student will be withdrawn from all nursing courses.

 Internal control considerations, if applicable: N/A