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coverageis certainly desirablein a Level III traumafacility. However,the requirement
that this criterion become"essential"when only routine or limited neurosurgical
coverageexits will be unobtainablefor most Level III facilities. With the current
shortageof neurosurgeons,
the requirementto havea neurosurgeon"bedsidewithin 30
minutesof an emergencyrequest"when a facility only hasroutine or limited coverage
simply is not possible.
Therefore,THA recommendsthat proposedSection157.125(x)(B)(1)(c)be revisedto
read: Neurosurgerycoverageis desiredin a Level III, but thesecriteria are"essential"
when a Level III hasfull-time neurosurgicalcoverage.
Trauma Nurse CoordinatorfTrauma Pro2ram Mana2er ReQuirement- Level IV
Trauma Facility Criteria
ProposedSection157.125(y)(A)(2)(c) requiresthat "traumaprogramsshouldhavea
minimum of 0.8 FTE dedicatedto the traumanursecoordinator/traumaprogrammanager
position" (TNC/TPM). THA agreesthat this position is imperativefor the successof the
traumaprogram. However,the proposedTNC/TPM staffing ratio for the smaller,rural or
remotely-locatedLevel IV traumafacilities is overly burdensome.With Texasin the
throesof a severenursing shortage,nursesin someLevel IV facilities arerequiredto
"wear many hats" - andthey wear them safely. To mandatethat TNC/TPM in all Level
IV facilities dedicate32 hoursa week to traumaactivities may result in non-productive
useof time. This especiallywould be true for the very small facilities, suchasthe
Critical AccessHospitals.
Sincethereis vast differencein Level IV facilities relating to size,location and number
of traumavisits per month,the criterion for the amountof time dedicatedto the
TNC/TPM position shouldbe revisedto allow for variancein rural and urbanLevel IV
facilities. Insteadof mandatinga specific ratio for rural facilities, the amountof time
requiredfor the TNcfrPM position could be determinedutilizing many of the factors
listed in the Nurse Staffing Rulesof the TexasHospital LicensingRules,adoptedin
2002. (See25 TEXASADMINISTRATIVE
CODE§133.41(o)(2)(F» Thesefactors include
patient characteristicsfor whom careis being provided,including numberof admissions,
dischargesand transfers;intensity of patientcarebeingprovided; scopeof services
provided; contextwithin which careis provided,including architectureand geographyof
the environment,andthe availability of technology;andthe staff characteristics,
including staff consistencyand tenure,preparationand experience,and the numberand
competenciesof clinical and non-clinical supportstaff.
Therefore,THA recommendsthat proposedSection157.125(y)(A)(2)(c)be revisedto
provide an alternativeto the mandated0.8 FTE dedicatedto the position ofTNC/TPM
for the smaller,rural or remotely-locatedLevel IV traumafacilities. In determiningsuch
alternative,THA recommendsconsiderationof factorslisted in the Nurse Staffing Rules
of the TexasHospital LicensingRules.
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