 1912-2018

Bismarck, ND 58503

701-335-6376

ND Administrative Code Article 33-36, Chapters 33-36-02, -03 and -04

Public Hearing

February 22, 2018 at 1:30 p.m. - Fort Totten Room, ND State Capitol

Good afternoon, my name is Carmen Bryhn. I am a Registered Nurse and I serve as the Executive Directorfor the North Dakota Nurses Association.

The North Dakota Nurses Association (NDNA) is the only professional organization representing all registered nurses (RNs) in North Dakota. The mission of NDNA is to advance the nursing profession by promoting professional development of nurses, fostering high standards of nursing practice, promoting the safety and well-being of nurses in the workplace, and advocating on health care issues affecting nurses and the public.

In regards to advocating on health care issues affecting the public,I would like to address some sections of the proposed revised EMS Administrative Rules that may need further consideration or more clarity.

The first consideration is the scope of practice the proposed rules provide for the community paramedic. Chapter 33-36-04-02 number 7 defines the scope of community paramedic to include “invasive and pharmacological interventions to reduce the morbidity and mortality associated with out of hospital medical conditions.” This concern is twofold in that:

1)this language appears to be identical to the paramedic scope of practice language on the prior section (6)

2)the interventions can be interpreted in a broad (and possibly inconsistent) manner therefore bringing up our concerns over public safety.

If the community paramedic role is different from the paramedic then this needs to be clarified and defined accordingly.

The second consideration is the curriculum for the community paramedic. On page 17-18 of the rules it states the department approves course curriculum, textbooks, and instructors. We would again advocate for the public’s safety to define a uniform curriculum with specific core competencies to the instruction.

As a final consideration, we would like the language for the supervision of the community paramedic to be consistent with other sections of code and administrative rules.

Thank you for your time and attention to our concerns. Please feel free to contact me if you have any questions.

Carmen Bryhn MSN, BSN, RN

Executive Director

North Dakota Nurses Association

SKILL Comparisons of Paramedic to PN / National Registry Paramedic
Curriculum / PN
Curriculum / Proficient in LPN Role
  1. Measuring Body Temperature
/ X / X / Yes
  1. Assessing radial and apical pulses
/ X / X / Yes
  1. Measuring Sp02 (02 Sats)
/ X / X / Yes
  1. Measuring Blood Pressure
/ X / X / Yes
  1. Documentation of Vital Signs
/ X / X / Yes
  1. Completing a bed bath
/ X / No
  1. Completing a tub bath
/ X / No
  1. Shower
/ X / No
  1. Making a medical bed
/ X / No
  1. Performing oral cares
/ X / No
  1. Foot or nail care
/ X / No
  1. Preparation of a sterile field and supplies
/ X / X / No*
  1. Applying sterile gloves
/ X / X / No*
  1. Applying and Removing PPE
/ X / X / No*
Medication Administration:
  1. 6 Rights:
Right Medication Right Route
Right Dose Right Time
Right patient Right Documentation / X / X / No*
  1. Oral
/ X / X / Yes
  1. Ophthalmic
/ X / X / No*
  1. MDI/Inhalers
/ X / X / Yes
  1. Preparing Injections Vial, Ampule, Powder
/ X / X / No*
  1. Administering an IM Injection
/ X / X / No*
  1. Administering an Intradermal
/ X / X / No*
  1. Administering Insulin
/ X / X / No*
  1. Mixing two insulins
/ X / No
  1. Blood Glucose Monitoring
/ X / X / Yes
  1. Insulin pens
/ X / X / No*
  1. Applying a nasal cannula or 02 mask
/ X / X / Yes
  1. Care of an artificial airway
/ X / X / Yes
  1. Suctioning
/ X / X / No*
  1. Nebulizer treatments
/ X / X / Yes
  1. Care of chest tubes
/ X / No*
  1. Head-to-Toe Assessments
/ X / X / No*
  1. Physical Examination (inspection, palpation, percussion, auscultation)
/ X / X / No*
Nutrition
  1. Aspiration precautions
/ X / X / Yes
  1. Administering enteral feedings via Nasoenteric, Gastrostomy, or Jejunostromy
/ X / X / No*
  1. Inserting a Nasoenteric Tube for Enteral Feedings
/ X / X / No*
  1. Administering a cleansing Enema
/ X / No
  1. Pouching an Ostomy
/ X / No
  1. Inserting a straight or indwelling catheter
/ X / X / No*
  1. Indwelling catheter care
/ X / No
  1. Closed catheter irrigation
/ X / No
  1. Assessment for risk for pressure ulcer development
/ X / No
  1. Applying dry and moist dressings
/ X / X / No*
  1. Performing wound irrigation
/ X / X / No*
  1. Applying an elastic bandage
/ X / X / No*
  1. Suture removal
/ X / No
  1. Wound drainage systems
/ X / No
  1. Staple removal
/ X / No
  1. Steri strip application
/ X / No
  1. Abdominal binder application
/ X / X / Yes
  1. Applying restraints
/ X / X / Yes
  1. Documentation for restraints
/ X / X / No*
  1. Patient privacy
/ X / X / Yes
  1. Hand washing
/ X / X / Yes
  1. Post-Partum Assessment
/ X / No
  1. Breastfeeding
/ X / No
  1. Newborn Assessment
/ X / No
  1. Newborn bath
/ X / No
  1. Pediatric Assessment
/ X / No
  1. Pediatric Medication Administration
/ X / No
  1. IV therapy- Observation of IV site and maintenance of flow
/ X / Yes
*According to the National Registry for Paramedics Curriculum, students learn these skills. However, we have found that the students in our program have either never learned the skill or are not proficient in the skill. These skills have been added to the paramedic to nurse bridge curriculum.