February 2, 2005
Ms. Karen Pollington, RN, Chairman
Montana State Board of Nursing
301 South Park Avenue
P.O. Box 200513
Helena, MT 59620-0513
Dear Ms. Pollington:
The American Nephrology Nurses' Association (ANNA) is an organization of over 11,000 registered nurses nationwide, including over 47 in Montana, who practice in all areas of nephrology. The majority of our members practice in outpatient dialysis settings. We are writing today to comment on the January 13 MAR Notice No. 8-32-64, proposed adoption of New Rules I-IX pertaining to delegation, specifically New Rule IX, Advance Delegation to a dialysis technician.
Dialysis technicians are the predominant caregivers in most outpatient dialysis facilities across the United States. We are pleased that the Board has recognized that there is a role for such unlicensed personnel in dialysis facilities in Montana and has appropriately addressed their role in the context of the delegation authority of their supervising registered nurse.
Having dealt with the role of unlicensed personnel in dialysis facilities in many states, ANNA developed position statements on delegation of nursing care activities and the role of unlicensed assistive personnel in dialysis settings. In addition, we prepared a joint position statement on the latter with the National Association of Nephrology Technicians/Technologists (NANT). These are attached for your reference. In addition, ANNA has long supported the certification of dialysis technicians and worked with NANT in the initial development of the Nephrology Nursing Certification Commission examination for dialysis technicians.
The specifications in New Rule IX for delegation to dialysis technicians, the tasks that may be delegated, and the medications they may administer are all consistent with the ANNA position statements. We therefore support the Board’s adoption of New Rule IX with regard to delegation of advanced nursing tasks to dialysis technicians.
We hope this information is helpful to the Board.
Lesley C. Dinwiddie, MSN, RN, FNP, CNN