SUCON Complaint

SUPERIOR COURT OF WASHINGTON FOR KING COUNTY

EMMA CARLSON, individually; CASEY CHATHAM, individually; STEPHANIE LOPEZ, individually; SHELBY STEPHENS, individually, Plaintiffs, v. SEATTLE UNIVERSITY, a Washington corporation; Defendant.

No.

COMPLAINT FOR DAMAGES Plaintiffs allege:

I. Parties

1.1 Plaintiffs were all college graduates who aspired to build careers in nursing and healthcare. In 2019 and 2020 they selected Seattle University’s College of Nursing (“SUCON”) based on the school’s reputation and its offering of advanced degrees for students who were not already registered nurses (RN), or who did not have Bachelor of Science in Nursing (BSN) degrees

1.2 SUCON offered a Doctor of Nursing Practice (DNP), which is a four year program, and a Master’s in Science of Nursing (MSN) degree after completion of five quarters of the DNP

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

program. These are considered “entry level” programs because they offer “college graduates with no health care background the opportunity to… become advanced practice nurses.” 1

1.3 Plaintiff Emma Carlson is a resident of Phoenix, Arizona

1.4 Plaintiff Casey Chatham is a resident of Kitsap County, Washington.

1.5 Plaintiff Stephanie Lopez is a resident of Pierce County, Washington.

1.6 Plaintiff Shelby Stephens is a resident of San Luis Obispo, California.

1.7 Defendant Seattle University is a Washington non-profit corporation with its principal place of business in Seattle, King County, Washington.

II. Jurisdiction and Venue

2.1 The Superior Court of King County, State of Washington, has subject matter jurisdiction over this action pursuant to RCW 2.08.010.

2.2 Jurisdiction and venue are proper in and for the Superior Court of Washington, King County because the principal place of business of Seattle University is located in Seattle and the acts and omissions giving rise to Plaintiff’s claims occurred in King County, Washington

2.3 This action was commenced within the applicable statutes of limitations.

III. Facts

Background on Licensing and Accreditation in Nursing Education

3.1 Like most states, Washington has regulated nursing education and the profession of nursing for decades.

3.2 Since at least 1994, the Nursing Care Quality Assurance Commission (“NCQAC”), a part 1 https://www.seattleu.edu/nursing/dnp/apni/

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

of the Department of Health (“DOH”), has had the responsibility to “regulate the competency and quality of professional health care providers … by establishing, monitoring, and enforcing qualifications for licensing, consistent standards of practice, continuing competency mechanisms, and discipline.” RCW 18.79.010.

3.3 One of NCQAC’s duties is to evaluate and approve nursing education programs. RCW 18.79.110.

3.4 NCQAC’s administrative philosophy is that “quality nursing education provides the foundation for safe and effective nursing practice” in order to “meet current and future nursing needs of the public.” WAC 246 840 500

3.5 Similarly, under WAC 246 840 505, NCQAC approves nursing education programs to “Assure preparation for the safe and effective practice of nursing by setting minimum standards for nursing education programs preparing persons for licensure,” and “Assure graduates of nursing education programs are educationally prepared for licensure at the appropriate level of nursing practice.”

3.6 NCQAC’s oversight is important for patient safety and public health broadly.

3.7 Nursing education programs are also required to be accredited “by a United States Department of Education approved regional accrediting body or national institutional accrediting body.” WAC 246 840 511.

3.8 “Any nursing education program not having national nursing education accreditation must disclose to students in all publications describing the program that it lacks national nursing education accreditation and this may limit future educational and career options for the students.” WAC 246 840 511.

3.9 Due to different licensing and practice restrictions in each state, these accreditation and

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

transparency requirements assure that students are informed and may utilize their education broadly. See, e.g., WAC 246-840-505(4) (one purpose of NCQAC approval is to “Facilitate interstate endorsement of graduates of commission approved nursing education programs”).

3.10 Any substantive changes to a nursing education program “must be presented to the commission for approval at least three months prior to implementation” via a substantive change request. WAC 246 840 554.

3.11 In this case, SUCON advertised, promised, and enrolled students for a curriculum and degree it was neither accredited nor licensed to offer and which never attained accreditation or licensure. Bait, Switch, Trap

3.12 In October of 2019, SUCON staff approved a curriculum and plan to award a Master’s in Science of Nursing (MSN) degree after completion of five quarters in the Doctor of Nursing Practice (DNP) program, which is a four year program.

3.13 Plaintiffs and other students in the MSN/DNP program had college degrees but did not have BSN or RN degrees, and therefore could not practice as nurses. The MSN would allow them to sit for the NCLEX exam, obtain nursing licenses, and work as nurses after a little over a year into the program, and receive the purported benefits of a master’s level degree.

3.14 On April 21, 2020 SUCON issued a letter to incoming DNP students (the 2024 graduating cohort) stating “we recently received approval from our University Academic Assembly to provide you the opportunity to earn an entry level Master’s degree while pursuing your RN,” and “earning your MSN from SU will not increase the overall length of your DNP

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

program.” 2

3.15 On May 4, 2020, the Associate Dean for Graduate Programs wrote to all current DNP students (the 2023 cohort): “we are pleased to let you know that the Board of Trustees approved our curriculum revision on April 30, 2020. Thus, when you complete the 4 DNP courses that are included in the new entry level MSN, you will be eligible to be awarded an MSN degree.” 3

3.16 These communications were false.

3.17 SUCON had not submitted a substantive change request to NCQAC, much less received approval to offer the entry level MSN degree.

3.18 SUCON had not submitted a substantive change request for accreditation by the Commission on Collegiate Nursing Education (“CCNE”), much less received accreditation to offer the entry level MSN degree.

3.19 In addition to the above letters, a 2020 2021 curriculum summary noted “Apply for MSN graduation by Oct 1,” and “Upon completion of NURS 6014, MSN will be awarded.” 4 3.20 These statements were false.

3.21 SUCON had not submitted a substantive change request to NCQAC, much less received approval to offer the entry level MSN degree.

3.22 SUCON had not submitted a substantive change request for accreditation by CCNE, much less received accreditation to offer the entry level MSN degree.

3.23 Despite its failure to attain accreditation or licensure for the entry level MSN program, SUCON marketed, advertised, recruited, and enrolled students in the MSN/DNP program 2 Ex. 1. 3 Ex. 2. 4 Ex. 3.

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

through the offer of an MSN degree, on its website and via other electronic, written, and verbal communications.

3.24 For example, informational materials on degree objectives, course requirements, course overviews, course objectives, grading scales, and estimated fees and costs for students, all referred to the MSN degree. 5

3.25 SUCON began accepting graduate school level tuition from the 2024 cohort based on an unapproved MSN degree.

3.26 On May 27, 2020, NCQAC issued a Letter of Decision to Kristen Swanson, Dean of SUCON, requiring that SUCON: 6

1. “Remove ‘End of MSN Pre Licensure Year’ from the syllabus because the entry level MSN has not been approved by the Commission.”

2. Include on the SUCON website a statement “pending NCQAC approval” for any courses not having approval.

3. Submit a substantive change request for the entry level MSN program prior to implementation.

4. Include 700 total clinical hours for an entry level MSN degree, citing Washington law. WAC 246 840 531 (1)(a)(iii) requires “At least six hundred hours” for BSN programs and (2)(b)(ii) requires “At least one hundred hours for graduate nursing education programs.”

3.27 SUCON did not modify its syllabus.

3.28 SUCON did not inform current, incoming, or prospective students that the school was not 5 Ex. 4. 6 Ex. 5.

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

licensed or accredited to offer the advertised MSN degree.

3.29 SUCON did not immediately submit a substantive change request for the entry-level MSN program prior to implementation the school had already purported to implement the program.

3.30 SUCON did not agree to the express requirement for 700 hours in Washington Administrative Code.

3.31 On June 19, 2020, NCQAC issued a Letter of Decision to Dean Swanson denying SUCON’s request to apply 600 clinical hours for an entry level MSN program. 7

3.32 On August 10, 2020, SUCON finally submitted a Substantive Change Request to NCQAC “to be effective 6/15/2020” (retroactively), regarding the proposed entry level MSN degree. 8

3.33 On September 18, 2020, NCQAC issued a Letter of Decision deferring approval of the entry level MSN degree pending “inclusion of 700 clinical hours” to align with State law, and syllabi and course content modifications. 9

3.34 WAC 246-840-531 requires 600 clinical hours for a BSN, and an additional 100 clinical hours for “graduate nursing education programs.”

3.35 On October 2, 2020, SUCON responded by explaining, “To meet the 100 additional clinical hours required for an MSN, in the latter two quarters of the AME program, we include faculty planned practice experiences…” with an “e Portfolio” of stored assignments. In other words, there was no additional 100 clinical hours.

3.36 SUCON did not inform current, incoming, or prospective students that the school was not 7 Ex. 6. 8 Ex. 7. 9 Ex. 8.

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

licensed or accredited to offer the advertised MSN degree.

3.37 On October 27, 2020, SUCON’s accreditation organization, CCNE, wrote Dean Swanson requiring additional reporting before accreditation of the entry level MSN program. 10

3.38 On November 20, 2020, NCQAC issued a Letter of Decision to Dean Swanson deferring approval of the entry level MSN program, and requesting information: 11

1. Describe how the ePortfolio meets masters level clinical practice hour requirements, ensures that masters level competencies are built upon and additive to distinct and measurable bachelors level competencies, avoids awarding identical credits across degree platforms, and ensures students are not over scheduled; 2. Provide CCNE communications regarding the proposed Prelicensure AME; and 3. Provide examples of similar program(s) (curriculum plans) used in the development of the proposed Prelicensure AME, including the number of practice hours.

3.39 SUCON did not inform current, incoming, or prospective students that the school was not licensed or accredited to offer the advertised MSN degree.

3.40 On December 18, 2020, NCQAC issued a Letter of Decision reminding SUCON to submit its response to CCNE “at the time the report is submitted to CCNE,” citing the “timelines described in WAC 246 840 556.”

3.41 Despite this reminder and direct citation to applicable law, SUCON did not provide NCQAC its report to CCNE.

3.42 On January 21, 2021, NCQAC issued a Letter of Decision to Dean Swanson stating: 12

The Panel noted the AME could not be approved based on the current documents presented to the Panel. The Panel deferred approval of the prelicensure AME program and requested clarification of program information provided to the Panel. Please provide the following*:

1. Describe how the MSN ePortfolio assignments are an application of practice; 2. Provide a table of MSN ePortfolio assignments associated with clinical placements; 3. Provide assignment details for NURS 6120, Population Based Health Care and AME Capstone project; 10 Ex. 9. 11 Ex. 10. 12 Ex. 11.

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

4. Clarify clinical hours per credit in NURS 5051, 6120, and 6020. It appears these courses are a combination of theory and clinical. Please be explicit in describing the allocation of time for all course components. It should be clear how clinical hours are calculated in all courses and reflected in all applicable syllabi;

5. Provide clarification how students can meet the clinical and theoretical time demands of the AME program; and

6. Clarify how:

a. master’s level competencies are built upon and additive to distinct and measurable bachelors level competencies; and b. awarding identical credits across degree platforms addresses/separates bachelors, masters, and doctoral level competencies.

3.43 In addition, NCQAC would consider approval of the proposed entry level MSN program as a graduate entry BSN program, as that was exactly what the 600 clinical hours qualified for.

3.44 SUCON did not inform current, incoming, or prospective students that the school was not licensed or accredited to offer the advertised MSN degree.

3.45 On January 26, 2021, Dean Swanson emailed NCQAC “We are feeling at an impasse” on the MSN program.

3.46 Dean Swanson requested to have the program “reviewed as an innovations proposal,” stating “We have an excellent program,” and citing 96% NCLEX pass rates in 2020.

3.47 However, 2021 NCLEX pass rates for that same program (2024 cohort) would dip to 76.71%, lower than Gonzaga, Northwest University, PLU, SPU, UW, Walla Walla University, and WSU.

3.48 In the January 26, 2021 email, Dean Swanson indicated that SUCON was still waiting on CCNE’s response on the program.

3.49 SUCON did not inform current, incoming, or prospective students in any fashion that the school was not licensed or accredited to offer the advertised MSN degree.

3.50 On February 10, 2021, CCNE wrote Dr. Swanson, after reviewing SUCON’s additional

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

materials, and “determined that additional reporting is required.” CCNE wrote that “a compliance concern remains relative to “complete clinical practice experiences” and “sustained clinical experiences designed to strengthen patient care delivery skills at the master’s level.” “Due to the severity of the concern,” the standards for degree certification were not met. 13

3.51 SUCON did not promptly forward this letter from CCNE to NCQAC as required by WAC 246 840 556.

3.52 SUCON did not inform current, incoming, or prospective students that the school was not licensed or accredited to offer the advertised MSN degree.

3.53 On March 1, 2021, SUCON leadership held an optional “All Cohort Meeting” by Zoom, to explain that SUCON could not award the promised MSN degrees. Dean Swanson stated, “We have come to realize that the Washington Department of Health is unlikely to ever write us a thank you letter and continuously requiring more, however, they were the ones that said to us why don’t you just ask us for permission to offer a bachelor’s degree.” Another faculty member described SUCON as “ahead of the curve for Washington.” 14

3.54 On March 15, 2021, SUCON issued a letter to its students formally announcing that “NCQAC [Nursing Care Quality Assurance Commission, a department of DOH] has declined to approve our proposed entry level MSN degree.” SUCON refers to this as “NCQAC’s refusal” and “NCQAC’s denial” as “part of the normal process for developing new academic programs in the highly regulated field of nursing education.” 15

3.55 In both the March 1 and March 15 communications to students, SUCON portrayed itself 13 Ex. 12. 14 Ex. 13. 15 Ex. 14.

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

as the victim of undue local regulation, and did not disclose to students that its national accrediting body also declined to approve the entry level MSN degree.

3.56 SUCON did not disclose to students the above described reasons why neither NCQAC nor CCNE approved the entry level MSN degree.

3.57 SUCON did not disclose to students that it failed to even request authority to offer the MSN program before advertising and promising it to students.

3.58 On April 8, 2021, NCQAC emailed Dean Swanson requesting SUCON’s response to CCNE’s October 27, 2020 letter regarding the proposed MSN program, which was due by January 25, 2021 SUCON’s failure to contemporaneously provide its response to CCNE violated WAC 246 840 556

3.59 On April 16, 2021, NCQAC issued a Letter of Decision accepting closure of the proposed MSN program, stating it “looks forward to receiving the BSN proposal.”

3.60 On April 23, 2021, NCQAC issued SUCON a formal Letter of Concern for “Repeated program violations” of applicable Code provisions, WAC 246 840 556 and WAC 246 840-554. “The Panel noted a troubling pattern of late submission of documents, followed by the Panel requesting the nursing program to submit outstanding documents, and repeated reminders by the Panel to the nursing program of WAC requirements related to submissions of program information.” 16 NCQAC cites as examples:

1. Letter of Decision May 27, 2020 reminding SUCON to submit a substantive change request for the entry level MSN degree “prior to implementation.”

2. Letter of Decision August 20, 2020 reminding SUCON that substantive change requests must be submitted “at least three months prior to implementation.”

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

(SUCON had attempted to make its substantive change request retroactive to June.)

3. Letter of Decision December 18, 2020 reminding SUCON to submit to NCQAC its response to CCNE

3.61 The Letter of Concern summarizes: “WACs 246 840 554 and 246 840 556 contain mandatory obligations with specific timelines for document submission. The nursing program has repeatedly submitted documents outside the required timelines despite regular Panel reminders and requests.”

3.62 In conclusion: The Panel expressed concern regarding the pattern of non compliance by the nursing program despite multiple verbal and written reminders and requests. The Panel encourages the program to review WACs 246 840 554 and 246 840 556 and to submit future documents in accordance with WAC timelines. Continued violations of these mandatory requirements are actionable up to and including changes to the approval status of the nursing program. (See WAC 246-840-556(1)(d), 246-840- 558(4)(c), (4)(e)).

3.63 On May 3, 2021, NCQAC notified SUCON that it was opening a complaint investigation “to determine if the minimum nursing education standards are being met.”

3.64 On May 26, 2021, NCQAC issued a letter to Dean Swanson regarding its investigation into potential violation of nursing education rules. NCQAC required that SU respond to more than twenty allegations. 17

3.65 On June 17, 2021, NCQAC approved the BSN degree in lieu of SUCON’s promised MSN degree.

3.66 This means that students could obtain a bachelor’s degree, when they had been paying graduate level tuition and taking courses needed only for the promised master’s program.

3.67 DOH investigator Erin Bush completed her investigation and report on October 14, 2021. 18 17 Ex. 16. 18 Ex. 17.

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

3.68 On November 22, 2021, NCQAC issued a Letter of Decision to Dean Swanson accepting the complaint investigation report, and issued findings: 19

The Panel determined violation of WAC 246 840 512(3) occurred: (3) Program information communicated by the nursing education program must be accurate, complete, and consistent.

The Panel determined violation of WAC 246 840 516(6) occurred: (6) The nursing education program shall provide accurate information to students and the public.

Misleading and inaccurate information was provided to students and the public through the college of nursing website, emails and letters to students, syllabi, the 2020 21 college catalog, and transcript of the APNI Year All cohort Zoom meeting held Monday, March 1, 2021.

3.69 NCQAC determined the violations were founded, but declined to take further action within its purview because by then SUCON had finally corrected the violations.

3.70 Students in both the 2023 and 2024 cohort made critical life and financial decisions in reliance on SUCON’s false promise of an MSN degree.

3.71 Some SUCON students left believing they had earned and would be awarded the MSN and that degree would meet their needs.

3.72 Other SUCON students left the school to finish their licensing degree at an institution they trusted.

3.73 Many other SUCON students preferred to leave but felt trapped because, with only a BSN for their work, they would have to start over on a doctorate or master’s program at a new institution. Due to the variability in higher level nursing education, much of their existing class work was not transferable to other programs. These students were therefore locked

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

in to SUCON’s tuition for several more years.

3.74 For the BSN degree that they would eventually receive, SUCON students had multiple lower cost options than private, graduate level tuition at SUCON.

Emma Carlson

3.75 Emma Carlson was a college graduate and aspiring nurse who in 2020 enrolled in the SUCON MSN/DNP program (2024 cohort).

3.76 Ms. Carlson relied on SUCON’s promise of an MSN degree when she decided to enroll, pay graduate level tuition, and study at SUCON.

3.77 After SUCON disclosed in March 2021 that it could not award the MSN degree, Ms. Carlson left the program to work for a year as a nurse before enrolling in another MSN program at a school she could trust.

3.78 As a direct and proximate result of SUCON’s deceptive practices, misrepresentations, fraud, and other misconduct, Ms. Carlson sustained damages in lost earnings, lost earning capacity, tuition, living expenses, and other general and special damages to be proven at the time of trial.

Casey Chatham

3.79 Casey Chatham was a college graduate and aspiring nurse who in 2020 enrolled in the SUCON MSN/DNP program (2024 cohort).

3.80 Ms. Chatham relied on SUCON’s promise of an MSN degree when she decided to enroll, pay graduate level tuition, and study at SUCON.

3.81 After SUCON disclosed in March 2021 that it could not award the MSN degree, Ms. Chatham elected to stay despite serious concerns over the competence and integrity of SUCON administration. She feels she has no choice but to complete the DNP at SUCON,

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

with several more years of tuition and work, because much of her credits, tuition, time, and work at the SUCON program would be wasted if she transferred.

3.82 As a direct and proximate result of SUCON’s deceptive practices, misrepresentations, fraud, and other misconduct, Ms. Chatham sustained damages in lost earnings, lost earning capacity, tuition, living expenses, and other general and special damages to be proven at the time of trial.

Stephanie Lopez

3.83 Stephanie Lopez was a college graduate and aspiring nurse who in 2020 enrolled in the SUCON MSN/DNP program (2024 cohort).

3.84 Ms. Lopez relied on SUCON’s promise of an MSN degree when she decided to enroll, pay graduate level tuition, and study at SUCON. She turned down other opportunities, including entry into Johns Hopkins’ prestigious nursing program, specifically because SUCON offered two degrees.

3.85 After SUCON announced it would not be awarding MSN degrees in 2021, Ms. Lopez decided she could no longer trust the school. She left SUCON with a BSN degree and significantly limited career opportunities and income

3.86 As a direct and proximate result of SUCON’s deceptive practices, misrepresentations, fraud, and other misconduct, Ms. Lopez sustained damages in lost earnings, lost earning capacity, tuition, living expenses, and other general and special damages to be proven at the time of trial.

Shelby Stephens

3.87 Shelby Stephens was a college graduate and aspiring nurse who in 2019 enrolled in the SUCON MSN/DNP program (2023 cohort).

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

3.88 When SUCON published the requirements to be awarded the promised MSN degree, Ms. Stephens relied on that promise in meeting those course credits.

3.89 After meeting those requirements and relying on SUCON to award the MSN, Ms. Stephens elected to leave school and start working as a nurse in December 2020. But she was not able to start work because SUCON inexplicably at the time would not award the MSN.

3.90 Due to SUCON’s delays in even awarding a BSN in lieu of the MSN, Ms. Stephens could not start work as a nurse until September 2021.

3.91 As a direct and proximate result of SUCON’s deceptive practices, misrepresentations, fraud, and other misconduct, Ms. Stephens sustained damages in lost earnings, lost earning capacity, tuition, living expenses, and other general and special damages to be proven at the time of trial.

IV. Liability Consumer Protection Act

4.1 The above described conduct by Defendant constitutes unfair and deceptive practices in trade or commerce, affecting the public interest, and causing injury to Plaintiffs’ business and property.

4.2 Defendant’s conduct is injurious to the public interest, under RCW 19.86.093, because it violated WAC 246 840 500 to 583, which are expressly intended to protect the public

1. WAC 246 840 500 states the “philosophy governing approval of nursing education programs” as intended to “meet current and future nursing needs of the public.”

2. WAC 246 840 505 defines the purpose of NCQAC is in part to “Assure preparation for the safe and effective practice of nursing by setting minimum standards for nursing education programs preparing persons for licensure as registered nurses, practical nurses, advanced registered nurse practitioners, or for preparing nurses for

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

additional graduate education or higher levels of nursing practice.”

3. WAC 346-840-514 requires that the “purpose and expected outcomes of the nursing education program shall be stated clearly and must be available to the public in written form.”

4. WAC 246 840 516 mandates that a “nursing education program shall provide accurate information to students and the public. ”

5. WAC 246 840 553 states that the purpose of innovations in nursing education program approval is to “Assure innovative approaches or programs protect the public, ” and requires that innovative approaches “not compromise public protection.”

6. WAC 246 840 558 prohibits schools from “Providing false or misleading information to students or the public concerning the nursing program.”

4.3 These WAC provisions are under authority of RCW 18.79, which contains an express declaration of public interest:

It is the purpose of the nursing care quality assurance commission to regulate the competency and quality of professional health care providers under its jurisdiction by establishing, monitoring, and enforcing qualifications for licensing, consistent standards of practice, continuing competency mechanisms, and discipline. Rules, policies, and procedures developed by the commission must promote the delivery of quality health care to the residents of the state of Washington.

4.4 Defendant’s conduct is also injurious to the public interest because it has injured multiple people, and has/had the capacity to injure many other students, potential students, and the public.

V. Liability Fraud

5.1 The above described conduct by Defendant constitutes fraud by and including acts, omissions, concealments, and deceptions causing damage to Plaintiffs.

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

5.2 Defendant made false representations of material facts; was aware of their falsity; and intended that prospective, incoming, and current students rely upon them.

5.3 Plaintiffs were unaware these statements were false, relied upon them, had the right to rely upon them, and suffered damages as a result.

VI. Liability Negligent Misrepresentation

6.1 In the alternative, the above described conduct by Defendant constitutes negligent misrepresentation.

6.2 Defendant supplied information for Plaintiffs’ guidance that was false; Defendant knew or should have known the information was supplied to guide Plaintiffs; and Defendant was negligent in communicating false information.

6.3 Plaintiffs relied on the false information; Plaintiffs’ reliance was reasonable; and the false information proximately caused Plaintiffs’ damages.

VII. Damages

7.1 As a direct and proximate result of the above described conduct by Defendant, Plaintiffs suffered special damages for lost earnings, lost earning potential, loss of employment and employment opportunities, past tuition, cost of substitute education, financial aid, loss of use of property, living expenses, and other special damages in amounts to be proven at the time of trial.

7.2 As a direct and proximate result of the above described conduct by Defendant, Plaintiffs suffered emotional distress, injury to reputation, and other general damages in amounts to be proven at the time of trial. See Nord v. Shoreline Sav. Ass’n, 116 Wn.2d 477, P.2d 800 (1991).

STRITMATTER KESSLER KOEHLER MOORE 3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

7.3 Plaintiffs suffered other general and special damages in amounts to be proven at the time of trial.

VIII. Prayer for Relief

WHEREFORE, Plaintiffs pray for judgment against Defendant as follows:

1. For special and general damages in amounts to be proven at trial;

2. For costs and disbursements;

3. For attorney fees;

4. If Defendant brings any frivolous or unfounded defenses, for attorneys’ fees and costs pursuant to RCW 4.84.185 and/or Rule 11 of the Superior Court Civil Rules;

5. For statutory interest on the judgment from the date judgment is entered until paid in full;

6. For prejudgment interest on the special damages;

7. For prejudgment interest on liquidated damages;

8. For such other and further relief as the Court may deem just and equitable.

DATED this 17th day of November, 2022.

STRITMATTER KESSLER KOEHLER MOORE

/s/Andrew Ackley

Andrew Ackley, WSBA#41752 Co Counsel for Plaintiffs 3600 15th Ave W Ste. 300 Seattle, WA 98119 (206) 448 1777

PREMIER LAW GROUP

/s/ Patrick Kang Patrick Kang, WSBA # 30726 Co Counsel for Plaintiffs 1408 140th Pl NE Ste 100 Bellevue, WA 98007 3962 (206) 285 1743

STRITMATTER KESSLER KOEHLER MOORE

3600 15th Ave West, Suite 300 | Seattle, WA 98119 Tel: 206 448 1777

April 21, 2020

Dear Incoming APNI Students:

I would like to welcome you to the 2024 class of APNI to DNPs! The Seattle University College of Nursing APNI admission process is competitive, thus it is a tribute to you that you have been accepted into the program. This email is to let you know of some changes (1) to your overall program of study and (2) in the delivery of courses this summer.

1. We are grateful that we recently received approval from our University Academic Assembly to provide you the opportunity to earn an entry level Master's degree while pursuing your RN. The program will receive final review by the SU Board of Trustees at the end of April. The good news is that earning your MSN from SU will not increase the overall length of your DNP program. The new APNI program will be offered over five quarters rather than four, have a population health focus and will grant an MSN at the end. In fall of 2021, after successfully passing the RN licensing exam (NCLEX), you will be formally admitted into your chosen Nurse Practitioner program of study. You will be able to apply 14 credits from the APNI/MSN toward your DNP. I am attaching an overview of the new APNI/MSN program that will soon be published on our website. We are very excited about these changes and welcoming your inaugural APNI/MSN cohort

2. As you all know, the Covid-19 pandemic has necessitated the offering of classes in a remote format at Universities across the country. To keep our students and faculty safe, Seattle University has made the decision to continue in this format through summer quarter. What this means for your class is that you will take your first classes with us remotely, from home. As NURS 5041 contains a 'hands on' skills lab, faculty will work with you this summer to complete a virtual simulation physical assessment module. Then, over the week of September 14th, we will hold an intensive skills lab that will prepare you for your first hospital based experience in fall quarter. More details on how the skills lab will be orchestrated are forthcoming, however in the meantime, please keep the week of September 14th open for classes.

COLLEGE OF NURSING 901 12th Avenue, Seattle, WA 98122 | 206.296.5660 | nurse@seattleu.edu | seattleu.edu/nursing/

Many of you have already been contacted by the Academic Advisor for your cohort, Rebecca Severson (severson@seattleu.edu). Ms. Severson is holding several virtual advising and registration sessions throughout the months of April and May.

Missy Hancock, Graduate Program Coordinator (mhancock@seattleu.edu), can help you with other questions related to the overview of the DNP program and any campus related needs.

We look forward to virtually meeting you this summer and have our fingers crossed that we will properly welcome you to campus in September.

Sincerely, Bonnie H. Bowie, PhD, MBA, RN Professor and Associate Dean for Graduate Programs

COLLEGE OF NURSING

901 12th Avenue, Seattle, WA 98122 | 206.296.5660 | nurse@seattleu.edu | seattleu.edu/nursing/

TO: Current APNI students

FROM: Bonnie Bowie, PhD, MBA, RN Associate Dean for Graduate Programs

DATE: May 4, 2020

As you all know, amid the Covid 19 crisis all nursing schools in the area have suspended clinical rotations and are utilizing virtual simulation as a substitute. Along with several other Washington State nursing schools, Seattle University CON sent a request to the Department of Health to count simulation hours at a 2:1 ratio (there is quite a bit of research to support this ratio). The state approved this ratio for the BSN classes, however would only approve a 2:1 ratio for the APNI class if there was a plan to achieve 600 hours for your cohort (the proposed entry level MSN has 600 clinical hours built in).

Thus, to meet this requirement, we have arranged a 4 credit, 120 hour clinical course for this summer (Population Health Synthesis). Our partners at Swedish have agreed to provide 96 hours of hands on clinical. You will be assigned to either 8 hours per day, 3 days per week for 4 weeks or 12 hours per day, 2 days per week for 4 weeks. We will then add 16 hours of simulation at a 2:1 ratio for 32 more hours for a total of 126 hours. The university has agreed that there will be no cost to students for this 4-credit clinical course.

In addition, we are pleased to let you know that the Board of Trustees approved our curriculum revision on April 30, 2020. Thus, when you complete the 4 DNP courses that are included in the new entry level MSN, you will be eligible to be awarded an MSN degree. These courses are:

Questions:

What courses will I take this summer?

In addition to the 4-credit clinical course, you will take NURS 6004, Pharmacology for RNs, NURS 6130 Foundations of Nursing Knowledge and NURS 6120 Population based Health Care (moved to summer from fall quarter). Population based Health Care will provide the underlying theory for your population based clinical course.

COLLEGE OF NURSING

901 12th Avenue, P.O. Box 222000, Seattle, WA 98122 (206) 296 5660 seattleu.edu

SEATTLE U

Can I choose the specialty area for my clinical rotation this summer?

Yes, as soon as we know what the options are , we will send out a query to students to gather your ist, 2nd and 3rd choices for clinical areas/specialties .

When will I be able to take NCLEX?

As soon as grades are posted to your transcript, you will be able to sit for the NCLEX exam. Most likely in early September.

Will the deadline for passing NCLEX by the beginning offall quarter in order to progress in the DNP program be extended?

Yes, absolutely, extending the deadline on ly makes sense. The exact deadline will be determined by GCEC by the end of spring quarter.

What will the schedule be for summer clinicals ?

Per the nurse educator at Swedish, your clinical rotation will start the week of June 29 th , with shifts either days or evenings on Wednesday, Thursday and/or Friday for 4 weeks; either 3 8-hour shifts, or 2 12-hour shifts each week. For 8-hour shifts, there may also be a choice of days or evenings.

How will I manage the work in other classes during the 4 weeks of clinicals?

We have been meeting with the faculty who will be teaching your other courses and they are coming up with creative solutions, such as front and end loading material. They are committed to working with students

I have no doubt that you will all have more questions as we draw closer to summer term and we will communicate more information as itis made available to us Meanwhile, best wishes for a successful finish to spring quarter .

Sincerely,

Bonnie H. Bowie, PhD,

MBA, RN

Professor and Associate Dean for Graduate Programs

COLLEGE OF NURSING

901 12th Avenue, P.O Box 222000, Seattle, WA 98122 (206) 296 5660 seattleu.edu

SUMMER 2020

Course Meeting

NURS 6004 - Pharm for RNs Mondays HYB 10:10-12:10

NURS 6120 - Pop Based Health Care Tuesdays HYB 12:40-15:20

NURS 6130 - Foundations of Nursing Tuesdays HYB 9:20-12:10

NURS 5XXX - Pop Role Health Synthesis W/Th/F - clinical arranged Course Meeting

* Apply for licensure with DOH and register with Pearson Vue by July 15

** HESI review anticipated week of August 10th

*Sit for NCLEX after August 17. Deadline to be licensed TBD

NURS 6017 Health Care Econ & Finance Thursdays 12:15-14:45

NURS 6020 Epidemiology Tuesdays AM or PM

NURS 6024 Advanced Patho Tuesdays AM or PM

NURS 6110 Ethics & Social Justice Thursdays 8:00-11:20 Course Meeting

NURS 6001 Adv. Health Assess. Lab Thursdays AM or PM

NURS 6101 Adv. Health Assess. Lec Tue or Thur 8:00-9:40

NURS 6014 Critical Inquiry I Tue or Thur 12:50-16:10

NURS 6075 Differential Diagnosis Tue or Thur 9:50-12:20

FALL 2020 WINTER 2021 SPRING 2021

Course Meeting

NURS 6010 Health Care Policy Tuesdays 10:15-12:45

NURS 6190 Quality Improvement Thursdays 10:15-12:45

* Apply for MSN graduation by Oct 1

* Upon completion of NURS 6014, MSN will be awarded

* Back to typical program of study for your cohort/tracks

Admission Deposit {One time) $500

Estimated

DNP Fees and Cost

Matriculation Fee (one time) $150 by Vear Tuition ($835 per credit) $59,285 Program Specific fee ($512/quarter) $2,048 Recreation Fee ($100/quarter) $400 DNP YEAR I Technology Fee ($175/quarter) $700 Adm i ssion Deposit (RN Entry) $500 Graduate Activity Fee ($10/term) $40 Tuit i on ($835 per credit) *

STATE OF WASHINGTON DEPARTMENT OF HEALTH

Nursing Care Quality Assurance Commission PO Box 47864 Olympia, WA 98504-7864

May 27, 2020

Kristen Swanson, RN, PhD, FAAN

Dean and Professor

Seattle University College of Nursing P.O. Box 222000 Seattle, WA 98122-1090

Letter of Decision:

• Approved POC Option A for current APNI cohort to meet 600 hours of clinical practice in order for students to be eligible to sit for the NCLEX exam pending syllabus modifications* to NURS 5051, Population Role Synthesis, described below;

• Approved Option B as a contingency.

Dear Dr. Swanson:

The Washington State Nursing Care Quality Assurance Commission Nursing Program Approval Panel (Panel) met on May 21, 2020 to review Seattle University’s Plan of Correction (POC) related to the plan for the current APNI cohort to meet 600 hours of clinical practice in order for students to be eligible to sit for the NCLEX exam.

The Panel approved the POC Option A for the current APNI cohort to meet 600 hours of clinical practice in order for students to be eligible to sit for the NCLEX exam pending syllabus modifications* to NURS 5051, Population Role Synthesis. The modifications required include:

1. Remove “End of MSN Pre-Licensure Year” from the syllabus because the entry level MSN has not been approved by the Commission; and

2. Include in the syllabus how the clinical competencies in the NURS 5051 course will be evaluated. Please provide the revised syllabus in the progress report, due by June 22, 2020.

The Panel requires the program to confirm implementation of Option A for the current APNI cohort 600 hours of clinical practice in the June 22, 2020 progress report. The Panel acknowledged that if circumstances required Option B to be implemented, simulation hours would be slightly over 50% of total clinical hours, and the overage was approved.

Seattle University College of Nursing

May 27, 2020

The Panel requests information posted on the program website regarding nursing programs not having NPAP approval, to include the statement “pending NCQAC approval.” (WAC 246-840512(3)).

The Panel reminded the program to submit a substantive change request for the entry level MSN program prior to implementation. (WAC 246-840-554(3)). The Panel also advised the program that an entry-level MSN program requires 700 total clinical hours if an MSN degree is awarded. (WAC 246-840-531(1)(a)(iii) and 246-840-531(2)(b)(ii)).

If you have any questions, please contact Dr. Gerianne Babbo at 360-791-4607 or by email at gerianne.babbo@doh.wa.gov, or Dr. Sarah Bear at 360-489-5693 or by email at sarah.bear@doh.wa.gov.

Sincerely, Gerianne Babbo Ed.D, MN, RN Director, Nursing Education Nursing Care Quality Assurance Commission Washington State Department of Health

cc: President Provost

STATE OF WASHINGTON DEPARTMENT OF HEALTH Nursing Care Quality Assurance Commission PO Box 47864 Olympia, WA 98504-7864

June 19, 2020

Kristen Swanson, RN, PhD, FAAN Dean and Professor Seattle University College of Nursing P.O. Box 222000 Seattle, WA 98122-1090

Letter of Decision: Accepted APNI NURS 5051, Population Role Synthesis, syllabus revisions; Denied 600 clinical hours to meet clinical requirement for a pre-licensure MSN program for entry into practice as a registered nurse.

Dear Dr. Swanson:

The Washington State Nursing Care Quality Assurance Commission Nursing Program Approval Panel (Panel) met on June 18, 2020 to review Seattle University’s request for acceptance of the APNI NURS 5051, Population Role Synthesis, syllabus revisions and the request to consider 600 clinical hours to meet the requirement for a pre licensure MSN program for entry into practice as a registered nurse.

The Panel accepted the APNI NURS 5051, Population Role Synthesis, syllabus revisions. Priority I, of the April 16, 2020 directed plan of correction has been met. The Panel denied the request for 600 clinical hours to meet the requirements for a pre-licensure MSN program for entry into practice as a registered nurse.

The Panel looks forward to reviewing the program’s progress report due June 22, 2020

If you have any questions, please contact Dr. Gerianne Babbo at 360-791-4607 or by email at gerianne.babbo@doh.wa.gov, or Dr. Sarah Bear at 360-489-5693 or by email at sarah.bear@doh.wa.gov.

Sincerely,

Gerianne Babbo Ed.D, MN,RN

Gerianne Babbo Ed.D, MN, RN Director, Nursing Education Nursing Care Quality Assurance Commission Washington State Department of Health

cc: Provost President

STATE OF WASHINGTON DEPARTMENT OF HEALTH Nursing Care Quality Assurance Commission PO Box 47864 Olympia, WA 98504-7864

September 18, 2020

Kristen Swanson, RN, PhD, FAAN Dean and Professor Seattle University College of Nursing P.O. Box 222000 Seattle, WA 98122-1090

Letter of Decision: Deferred approval of Prelicensure Accelerated Master’s Entry (AME) program pending receipt of additional information* noted below; Deferred approval of MSN advanced practice program closure; Approved POC (July) follow-up information on APNI student hours summer 2020; Approved COVID curricular adjustments spring and summer 2020 follow-up report.

Dear Dr. Swanson:

The Washington State Nursing Care Quality Assurance Commission Nursing Program Approval Panel (Panel) met on September 17, 2020 to review Seattle University’s 1). Prelicensure AME program; 2). MSN advanced practice program closure; 3). POC (July) follow-up information on APNI student hours summer 2020; and 4). COVID curricular adjustments spring and summer 2020 follow-up report.

The Panel deferred approval of the Prelicensure AME program pending receipt of additional information* below:

1. Inclusion of 700 clinical hours in the AME program to align with WAC 246-840-531(1 iii) and (2 ii).

2. Syllabi grids need to consistently address BSN and graduate program outcomes; BSN and MSN Essentials; ANA Code of Ethics; and QSEN.

The Panel deferred approval of the MSN advanced practice program closure until the AME program is approved. Closure of the MSN program prior to approval of the AME would require the AME program to address WAC 246-840-510.

The Panel reminds the program of WAC 246-840-559 addressing program closure timeframes.

Kristen Swanson

September 18, 2020

2 of 2

The Panel approved the POC (July) follow-up information on APNI students hours summer 2020.

The Panel approved the COVID curricular adjustments spring and summer 2020 follow-up report and commended the program for the report detail.

The Panel notes that informal conversations and technical assistance with staff do not constitute panel approval. All final decisions and approvals are made by the NPAP.

If you have any questions, please contact Dr. Gerianne Babbo at 360-791-4607 or by email at gerianne.babbo@doh.wa.gov, or Dr. Sarah Bear at 360-489-5693 or by email at sarah.bear@doh.wa.gov.

Sincerely, Gerianne Babbo Ed.D, MN, RN Director, Nursing Education Nursing Care Quality Assurance Commission Washington State Department of Health cc: President Provost

Public Health – AlwaysWorkingforaSaferandHealthierWashington

October 27, 2020

Kristen M. Swanson, PhD, RN, FAAN Dean and Professor College of Nursing Seattle University 901 12th Avenue, PO Box 222000 Seattle, WA 98122 1090

Dear Dr. Swanson:

On behalf of the Commission on Collegiate Nursing Education (CCNE), I am writing to inform you that the CCNE Board of Commissioners reviewed the substantive change notification submitted on June 22, 2020 by the master’s degree program in nursing and the Doctor of Nursing Practice (DNP) program at Seattle University, and as a result of its review determined that additional reporting is required.

The Board had no concerns related to the teach out of the master’s level APRN program, the suspension of admissions to the pre licensure Advanced Practice Nursing Immersion (APNI) option, and the reallocation and reduction of credits within the DNP program

The Board directs the master’s program to submit a follow up report to demonstrate compliance with Key Elements III C and III H, as follows:

Demonstrate that master’s curricula are developed, implemented, and revised to reflect relevant professional nursing standards and guidelines, which are clearly evident within the curriculum and within the expected student outcomes (individual and aggregate); that all master’s degree programs incorporate The Essentials of Master’s Education in Nursing (AACN, 2011); and that graduate entry master’s program curricula incorporate The Essentials of Baccalaureate Education for Professional Nursing Practice (AACN, 2008) and appropriate graduate program standards and guidelines (Key Element III C). Specifically, the notification did not demonstrate how the pre licensure accelerated master’s entry track would appropriately incorporate leveling of both the Baccalaureate Essentials and Master’s Essentials through one course.

Demonstrate that the curriculum includes planned clinical practice experiences that enable students to integrate new knowledge and demonstrate attainment of program outcomes (Key Element III H). Specifically, the program must demonstrate that students in the pre licensure accelerated master’s entry track complete clinical practice experiences consistent with the American Association of Colleges of Nursing’s (AACN) The Essentials of Master’s Education in Nursing (Master’s Essentials) (2011) definition of the direct care role, including “sustained clinical experiences designed to strengthen patient care delivery skills” at the master’s level (pp. 8 9). In its glossary, the Master’s Essentials defines direct care as “nursing care provided to individuals or families that is intended to achieve specific health goals or achieve selected health outcomes. Direct care may be provided in a wide range of settings, including acute and critical care, long term care, home health, community based settings, and educational settings” (p. 33).

The follow up report must be received in the CCNE office on or before January 25, 2021. Please email the follow up report, along with appendices, if any, as PDF

attachmen t s to ccnereports @ccneaccreditation.org The report will be r e viewed by t h e CCNE Board of Commissione rs.

Please contact Lina Nandy, CCNE Associate Di rec t or, fo r guidance o r clarification , if needed She ca n be reac hed by telep hone at 202-887-6791 x245 or by emai l at LNandy@ccneaccreditation. org .

Si ncere ly ,

Mary

J a ne S. Hanson , Ph D, CRNP , CNS , FNP-BC , ACNS-BC , FAANP Ch a i r , CC NE Board of Comm issione rs

STATE OF WASHINGTON DEPARTMENT OF HEALTH Nursing Care Quality Assurance Commission PO Box 47864 Olympia, WA 98504-7864

November 20, 2020

Kristen Swanson, RN, PhD, FAAN Dean and Professor Seattle University College of Nursing P.O. Box 222000 Seattle, WA 98122-1090

Letter of Decision: Accepted CCNE accreditation letters for Post Graduate APRN Certificate and DNP programs; Accepted Plan of Correction (November) and requested additional information* noted below; Deferred Prelicensure Accelerated Master’s Entry (AME) program follow-up information addressing clinical hours requirement and requested additional information noted below**; and Accepted Prelicensure AME syllabi grid uniformity.

Dear Dr. Swanson:

The Washington State Nursing Care Quality Assurance Commission Nursing Program Approval Panel (Panel) met on November 19, 2020 to review Seattle University’s a). CCNE accreditation letters for the Post Graduate APRN Certificate and DNP programs; b). Plan of Correction (November); and c). Prelicensure AME program follow-up information addressing clinical hours requirement and syllabi grid uniformity.

The Panel accepted the CCNE accreditation letters for the Post Graduate APRN Certificate and DNP programs.

The Panel accepted the Plan of Correction (November) and requested follow-up information* noted below.

WAC 246 840 518 Results and analysis of student resources survey to be distributed Jan 2021. Analysis of survey due to NPAP March 1, 2021

WAC 246 840 512 Provide final Comprehensive Evaluation Plan See attached document with NPAP suggestions for the program to consider.

WAC 246 840 519 Student Rights and Responsibilities policy.

Public Health – AlwaysWorkingforaSaferandHealthierWashington

The Panel accepted the Prelicensure AME syllabi grid uniformity but deferred approval of the Prelicensure AME program and requested the following information**:

1. Describe how the ePortfolio meets masters level clinical practice hour requirements, ensures that masters level competencies are built upon and additive to distinct and measurable bachelors-level competencies, avoids awarding identical credits across degree platforms, and ensures students are not over-scheduled;

2. Provide CCNE communications regarding the proposed Prelicensure AME; and

3. Provide examples of similar program(s) (curriculum plans) used in the development of the proposed Prelicensure AME, including the number of practice hours.

If you have any questions, please contact Dr. Gerianne Babbo at 360-791-4607 or by email at gerianne.babbo@doh.wa.gov, or Dr. Sarah Bear at 360-489-5693 or by email at sarah.bear@doh.wa.gov.

Sincerely,

Gerianne Babbo Ed.D, MN, RN

Director, Nursing Education Nursing Care Quality Assurance Commission Washington State Department of Health

cc: President Provost

STATE OF WASHINGTON DEPARTMENT OF HEALTH Nursing Care Quality Assurance Commission PO Box 47864 Olympia, WA 98504-7864

January 21, 2021

Kristen Swanson, RN, PhD, FAAN

Dean and Professor Seattle University College of Nursing P.O. Box 222000 Seattle, WA 98122-1090

Letter of Decision: Accepted baccalaureate and master’s degree programs: 1). 2017 CIPR; and 2). CCNE response letter to 2017 CIPR; Deferred approval of Prelicensure Accelerated Master’s Entry (AME) program and requested clarification* of program information provided to the Panel.

Dear Dr. Swanson:

The Washington State Nursing Care Quality Assurance Commission Nursing Program Approval Panel (Panel) met on January 21, 2021 to review Seattle University’s: a). Baccalaureate and master’s degree programs: 1.) 2017 CIPR; and 2). CCNE response letter to 2017 CIPR; and b). follow-up information for the Prelicensure Accelerated Master’s Entry program (AME)

The Panel accepted the baccalaureate and master’s degree programs: 1.) 2017 CIPR; and 2). CCNE response letter to the 2017 CIPR.

The Panel noted the AME could not be approved based on the current documents presented to the Panel. The Panel deferred approval of the prelicensure AME program and requested clarification of program information provided to the Panel. Please provide the following*:

1. Describe how the MSN ePortfolio assignments are an application of practice;

2. Provide a table of MSN ePortfolio assignments associated with clinical placements;

3. Provide assignment details for NURS 6120, Population Based Health Care and AME Capstone project;

Kristen Swanson

January 25, 2021 Page 2 of 2

4. Clarify clinical hours per credit in NURS 5051, 6120, and 6020. It appears these courses are a combination of theory and clinical. Please be explicit in describing the allocation of time for all course components. It should be clear how clinical hours are calculated in all courses and reflected in all applicable syllabi;

5. Provide clarification how students can meet the clinical and theoretical time demands of the AME program; and

6. Clarify how:

a. master’s level competencies are built upon and additive to distinct and measurable bachelors level competencies; and b. awarding identical credits across degree platforms addresses/separates bachelors, masters, and doctoral level competencies.

The Panel indicated that, upon request by SU, it would consider approval of the proposed AME program as a Graduate Entry Baccalaureate of Science in Nursing program.

If you have any questions, please contact Dr. Gerianne Babbo at 360-791-4607 or by email at gerianne.babbo@doh.wa.gov, or Dr. Sarah Bear at 360-489-5693 or by email at sarah.bear@doh.wa.gov.

Sincerely, Gerianne Babbo Ed.D, MN, RN Director, Nursing Education Nursing Care Quality Assurance Commission Washington State Department of Health cc: President Provost

February 10, 2021

Kristen M. Swanson, PhD, RN, FAAN Dean and Professor College of Nursing Seattle University 901 12th Avenue, PO Box 222000 Seattle, WA 98122 1090

Dear

Dr. Swanson,

On behalf of the Commission on Collegiate Nursing Education (CCNE), I am writing to advise you that the CCNE Board of Commissioners reviewed the follow up report submitted on December 18, 2020 by the master’s degree program in nursing at Seattle University and as a result of its review determined that additional reporting is required.

The Board determined that the master’s degree program in nursing at Seattle University has demonstrated compliance with Key Element III C, but that a compliance concern remains relative to Key Element III H, and due to the severity of the concern, Standard III is not met.

The Board directs the master’s program to submit a follow up report to demonstrate compliance with Key Element III H, as follows:

Demonstrate that the curriculum includes planned clinical practice experiences that enable students to integrate new knowledge and demonstrate attainment of program outcomes (Key Element III H). Specifically, programs that have a direct care focus are to provide direct care experiences designed to advance the knowledge and expertise of students in a clinical area of practice. The program must demonstrate that students in the Accelerated Master’s Entry (AME) track complete clinical practice experiences consistent with the American Association of Colleges of Nursing’s (AACN) The Essentials of Master’s Education in Nursing (Master’s Essentials) (2011) definition of the direct care role, including “sustained clinical experiences designed to strengthen patient care delivery skills” at the master’s level (pp. 8 9). In its glossary, the Master’s Essentials defines direct care as “nursing care provided to individuals or families that is intended to achieve specific health goals or achieve selected health outcomes. Direct care may be provided in a wide range of settings, including acute and critical care, long term care, home health, community based settings, and educational settings” (p. 33). Direct care experiences are designed to prepare students for advanced nursing practice care

Though the follow up report provided examples of clinical experiences within the AME track, the report did not provide examples of direct care clinical experiences at the master’s level. The follow up report should provide examples of direct care experiences at the graduate nursing level, and the

number of direct care clinica l hours at the master ' s level that all students i n the AME track are required to complete.

Th e fo ll ow up r e port must be received in t he CCN E office on or before April 28 1 1Qll. Please email the follo w -up report , along wi th appendices , if any , as PDF attachments to ccnereports @ccneaccreditation.org . The report will be reviewed by the CCNE Board of Comm issioners.

As a reminder, prog rams are expected to comply with the current CCNE standards and procedures throughout the period of accreditation This includes ad vi sing CCNE in the e vent of any s u bstantive c hange in the nursing programs or of any major organizational changes that may affect the programs ' administration , scope , or quality. Substanti ve change notifications must be subm itted to CCNE no earlier than 90 days prior to implementation or occurrence of t he change , but no later than 90 days after implementation or occurr ence of the change. These reporting requirements are discussed further in the CC NE Procedures for Accreditation of Baccalaureate and Graduate Nursing Programs

Please contact Lina Nandy, CCNE Associate Director, for gu idance or clarification , if needed. She can be reac hed by telephone at 202-887-6791 x245 or by email at lNandy@ccneaccreditation.org .

Sincerely, Elizabeth Ritt , EdD , MSN , RN , NEA BC , CNE Chair , Board of Commissioners

cc: CCNE Board of Commissioners

APNI-YEAR-ALLCOHORTMEETING Monday,March1,2021 3:30PMviaZoom

INTRODUCTION

DR.BOWIE DeanSwansonandIwantedtohaveameetingwithyoualltoday,sowecouldtellyou alltogethertheprogress,orperhapslackthereofthatwe'vemadewithgettingthestatetoapprove entry-levelmastersProgram.Youmayknowthatayearandahalfagowewerequitepleasedwhenthe BoardofTrusteesapprovedamaster'sentryprogramforourAPNIprogram.Westartedthatworkabout twoandahalfyearsago,realizingthatwereallyneededtoawardadegreetofolkswhomightleaveafter thenewyearbecauseweusedtoeatmastersusedtobeshorterandwehardlyhadanybodyleaveoverthe courseof15yearsjustahandfulofpeopleand.Sowehavehadmorepeopleleaveandmanyhavecome backaswelltofinish,but.Anyway,wedidnotwantpeopleleavingwithoutadegree,andsowehad quiteabitofdebateinourgraduatecurriculumcommitteeandthenasubcommitteeandwherewe broughtin,studentsandothersaboutwhatthatdegreeshouldbe,andatthattimewedidthinkabouta BSN,Butwealsoweretoldthatwewouldhavetohavefolkscompletecorecoursesandthat'sa requirementSeattleuniversityforourtransferBSNstudentsandwedidn'twantpeopletohavetodothat and,inaddition,atthetime,ifpeoplewereenrolledtheminabachelor'sprogramtheymightnotbeable toreceivegraduate-levelfinancialaidsothatwasactuallyabigfactoramongstudentsthatwereona planningcommittee.

Anyway,wepursueddesigningamaster'swegotitthroughallthehoopsatSeattleuniversityand throughtheboardoftrusteesandthattookaboutsevenoreightmonths,sowewereveryoptimistic feelinggreatandthenthenexthurdlesforuswastogetitthroughourDepartmentofHealthnursing educationqualityassuranceprogramandouraccreditationbody.Wehavehitbarrierafterbarrierwiththe DepartmentofHealthandonthewiththishasgoneonnowforoverayear,wherewesubmitdocuments andtheyaskedalotofquestions.Andinitially,theyaskedsomereallygreatquestionsandthathelpedus toreallyshapetheprogramforthebetter.Sowekeptgoingbackandforthandsubmittingmoreand moredocumentsandinDecember,justbeforethebreakwesubmitted.Moredocumentstothemand [DeanSwanson]andIwerelikethisisitwegotitit'sperfectthey'regonnathey'regoingtoapproveit. Andtheytypicallymeettowardtheendofeachmonth,andtheymetinJanuaryandthensendusaletter sayingthat.Westillneededtodomorefortheprogramsofeelingthatwe'dhitabitofanimpassewith them.DeanSwansonandIsetupameetingwiththefolksfromtheDepartmentofHealthand.Basically, itboilsdowntoacoupleofthings,themostmajorpiecewasrequiringanotherhundredhoursofclinical practiceatthegraduatelevelappliedgraduatepractice.Wehadthoughtwemetthatrequirementwe knewthatwasarequirementof700hoursversus600.AndwhenwereadtheWACsandinterpretedthem andwentbackandforth,wereallythoughtwehititbuttheyreallywantmorehoursthatarereally associated with a clinical agency

Andso,atthatpoint,weregrouped.SpokewithfolksatSeattleUandhadameetingwithsomepeople justaweekagotodayactuallyaboutsomeoptionsandoneoftheoptionsthatIthatwearegoingto pursueoranoptionwearegoingtopursuenow,Becausewefeellikewejustcan'tknowwhatthestate wouldlikeustodoisaBSNinpassingbecausewearestilldeterminedtohavesomekindofdegreefor youall,whenwefinishedthehappeninghereandtakeNCLEX.

Sothatiswhereweareatthemomentandwethinkwemaygetbeabletogetaroundthecorner requirements,thoseareoneisethicsandoneistheology,andwedohaveanethicscoursethatyouwill takeitinthespring.Thetheologywe'restill-Negotiating.Sothere'sgoingtobesomebackandforthat theuniversitylevel,andthenwewillneedtosubmitsomethingagaintotheDepartmentofHealth,but theDepartmentofHealthishadsuggestedtousthatwemightconsideraBSN.

DEANSWANSON So[Dr.Bowie]andIwantedtoaddonething.Whenyousaid,theDepartment ofHealthrequired100graduatelevelclinicalhours,Iwanttomakeitclear,thesearenot100hoursthat wouldcounttowardsyournursepractitioner.Thesewouldbe100hoursworkinginleadershipordoing education,thesewouldbeatthelevelofwhattheyconsidertobemastersclinical.Wethoughtaboutit, andsaidthatitwasnotthepointofwhatwewereattemptingtodowewereattemptingtopulltogether anentrylevelmasters,whichisinfactawayofdoingbusinessandotherpartsofthecountry.Ihavea pointofreference,theDeanofColumbia[University]inNewYorkshe'sontheboardwithmeat SwedishandIaskedher:‘Whenyouputtogetheryourentrylevelmasters,HowdidtheNewYork departmentandhealthrespondandshesaid,withathankyouletterforlettingusknowlettingthem know.’Thatwasthesoullevelofscrutiny,theyhadattheStateDepartmentofHealth.Wehavecometo realizethattheWashingtonDepartmentofHealthisunlikelytoeverwriteusathankyouletterand continuouslyrequiringmore,however,theyweretheonesthatsaidtouswhydon'tyoujustaskusfor permissiontoofferabachelor'sdegreetoyourAPNIanystudents.Andwhen[Dr.Bowie]andIheard themsaythatourfirstresponsewaswellifweofferthemabachelor'sdegree,theycan'tgetstudent financialaid.Youcan'tgetfinancialaidforasecondbachelor's.Soinfrustration,Icalledtheheadof studentfinancialservicesforSeattleuniversityandIsaidtohimJeffisthereanywayourAPNIstudents couldearntheirbachelor'sdegree,whilethey'rewithusandstillbeabletogetfinancialaidandhis answerwasyeah-Aslongastheyareadmittedhisdoctoralstudents.Well,that'sallyouarecodedashis doctoralstudents,youarenotcodedasmasters,youarenotcodedasbaccalaureate,youarecodedas doctoralstudents.

Andthepieceherewouldbethatyouwouldforeverbenoted,asanAPNItoDNP,justasyour classmatesorsoon,knownasourRNtoDNPthestudentswhowillbeadmitted,ortheHSLthehealth systemsleaderstoDNPbutwhatyouallshareincommonis‘toDNP’andtheysaid,thepossibilityofa BSNinpassing,isfromafinancialaidstandpoint,notanissue.

WhereitisanissueatSeattleUniversityhastodowiththecorecurriculum.Anduntilwecanget permissiontoeitherfindawaytodothatinamodifiedfashionorhaveitdeclaredthatasdoctoral students,youarenotseekingabachelor'sdegree,youarejustbeinggrantedaBSNinpassing,giventhat you'vedonetheequivalentcourseworkontheway.

SoIknowthisallsoundsalittleconfusingbutit'stosaytoyouthatwehaveprettymuchtheMastersis notgoingtohappen.Threeyearsfromnow,whenourprofessionchangesitscriteriaforentryinto practiceit'syouknowyouallhearabouttheDNPessentialswellthereareactuallybachelor'sessentials, mastersessentials,andDNPessential’scurrentstate.

Andanothermonththedeansaregatheringfromacrossthecountry,andwearegoingtovoteonnew essentials,thatwilljustbetwo:oneforentryintopracticeasanRN,secondforentryintopracticeasan advancedpracticenurse.

Theywillbeagnostictodegrees.It'llbefocusedonhaveyoumettheessentials,tobeanadvanced practicenurse,haveyoumettheessentials,tobearegisterednurse,andatthattimeIcan'timaginethat wewouldrunintothesameissuesaboutwhetheryoucanbegrantedaMasterstobecomeanRNora bachelor'stobecomeanRNandthediscussionthatIhaveparticipatedinisthatitwillbeamootpoint theyreallydon'tcarewhatyourdegreeissolongasyoumeetthecompetenciestobeanRN.Then,when youcompleteyourdoctorateyou'vemetthecompetenciestobeanadvancedpracticenurse.

So,youareadmittedtoanAPNIneedaDNPprogramattheendoffivequarters,wesignadocument thatsays,youcansitforyourRNlicense.That'sthewayit'sbeenalongit'sthewayitwillbe.Whatwe areattemptingtodoforyourgroupistoeventuallygetthepermissiontogiveyouaBSNin passing,assoonaswecangetitthroughtheuniversity.Idon'tanticipatewe'llhavetroublewitha state,becausetheyaskedustodoit,andwhenwehadthedoctoralprogramaccreditedlastyear,our accreditingbodylookedattheAPNItoDNPprogramandthescrutiny,theyputusthroughwas:Didthe APNIprogrammeettheessentialeducationforabachelor'sdegree?andouraccreditingbodyapprovedit asmeetingtheessentialsforabachelor'sProgram.

Soweanticipateit'llbeamatteroflettingtheCCNEknowthatindeedwe'regoingtodoaBSNin passing.It'llbeamatterofsayingtotheDepartmentofHealthyouhadagreatideawe'rereadytodoit, thebiggestchallengeweseeinfrontofusisSeattleuniversityandtheirrequirementsforcorecoursesat theundergraduatelevel.Andwe'regoingtoseewhetherornotthey'veallmuchprettymuchsaidthat yourethicscourseisgoingtobefineasoneofthetwocourses,theothercoursethat'sunderdiscussion istheologyandwe'llseewhereitgoes.

DR.BOWIE Ithinkthebottomlineiswherewe'reaheadofthecurveforWashingtonnowother Statesaredoingthisandwegavethemalistofadozenorsoprogramsthathaveverysimilarentrylevel masters,butwe'rejustaheadinWashington,whentheonlyprograminthestatethatwasreallyproposing todothat. [QUESTION AND ANSWER PORTION FOLLOWED]

March15,2021

DearStudents;

Asyouknow,sinceJanuary2019,theCollegeofNursinghasbeendevelopingand seekingapprovaltoawardabenchmarkdegreetostudentscompletingthepre licensureportionoftheAdvancedPracticeNursingImmersion(APNI)toDoctorof NursingPractice(DNP)program.Aftermonthsofstakeholdermeetingsand listeningsessions,thecollegechosetopursuea pre-licensure entrylevelMasterof ScienceinNursing(MSN)degreeforthosecompletingtheAPNI.Theuniversity’s BoardofTrusteesapprovedthisproposeddegreelastspring,andthecollegehas spentthelastseveralmonthsseekingapprovalforthedegreefromtheWashington StateNursingCareQualityAssuranceCommission(NCQAC).Thiswouldbethefinal stepinthelengthyapprovalprocess,atimelineofwhichIhaveattachedfor reference

Unfortunately,andasDeanSwansonandIsharedwithyouatarecentmeeting,the NCQAChasdeclinedtoapproveourproposedentry levelMSNdegree.Bythe conclusionofourlastmeetingwithNCQACrepresentativesinFebruary,itbecame apparenttousthattheywouldonlyapprovea post BSN Masters,similartoanMSN inNursingEducationoraClinicalNurseLeader.

WeconsideredrevisingtheproposalagaintomeetNCQAC’sadvancedpractice requirements,buttheentrylevelpre licensureMSNdegreewasnevermeantto preparestudentsfortheseadvancedpracticeroles.Offeringpost baccalaureate educationwoulddeviatefromtheoriginalintentoftheproposedprogram, requiringmorecredits,morecontent,andmoreapprovals.

NotwithstandingtheNCQAC’srefusaltoapproveourproposedentry levelMSN degree,theuniversityremainscommittedtosupportingtheoriginalgoalof GraduateCurriculumEvaluationCommittee(GCEC)andthecollegetoawardDNP studentsanacademicdegreeforentryintonursingpracticeattheendoftheAPNI program.Ratherthanattempttoexpandtheproposedentry levelMSNdegreeintoa post baccalaureateMSN,thecollegehasbeguntoexplorethepossibilityofoffering aBachelorofScienceinNursing(BSN)asabenchmarkintheAPNItoDNPprogram. Currently,theOfficesoftheProvost,Registrar,StudentFinancialServices, InstitutionalResearch,andtheUniversityCoreCurriculumareallinvestigatingthe feasibilityofawardingaBSNtoAPNItoDNPstudents.TheCoreCurriculum ExecutiveCommitteewillsoonmeettoconsideracceptingcorecurriculumcourses fortheBSNinpassing(theologyandethics).Wewillletyouallknowtheresultsand nextstepsaswehearthem.

COLLEGE OF NURSING

901 12th Avenue, P.O. Box 222000, Seattle, WA 98122 (206) 296 5660 seattleu.edu

SEATTLEU

Although NCQAC' s denial of our proposed degree is disappointing, it is part of the normal process for developing new academic programs in the highly regulated field of nursing education. We look forward to continuing to engage with you on this important topic as the process moves forward.

Sincerely, Bonn ie H . Bowie, PhD, MBA, RN, FAAN Professor and Associate Dean for Graduate Programs

COLLEGE OF NURSING 901 12th Avenue, P.O. Box 222000, Seattle, WA 98122 (206) 296 5660 seattleu.edu

STATE OF WASHINGTON DEPARTMENT OF HEALTH

Nursing Care Quality Assurance Commission PO Box 47864 Olympia, WA 98504-7864

April 23, 2021

Kristen Swanson, RN, PhD, FAAN

Dean and Professor Seattle University College of Nursing P.O. Box 222000 Seattle, WA 98122-1090

Letter of Concern: Repeated program violations of WAC 246-840-556(1)(a), (1)(b), (1)(d), and WAC 246-840-554(3).

Dear Dr. Swanson:

The Washington State Nursing Care Quality Assurance Commission Nursing Program Approval Panel (Panel) met on April 15, 2021 and issued a Letter of Concern regarding the Seattle University’s School of Nursing (nursing program) persistent submission of documents outside required timelines of WAC 246-840-556(1)(a), (1)(b), (1)(d), and WAC 246-840-554(3).

The Panel noted a troubling pattern of late submission of documents, followed by the Panel requesting the nursing program to submit outstanding documents, and repeated reminders by the Panel to the nursing program of WAC requirements related to submissions of program information. Examples are noted below:

May 27, 2020 Letter of Decision

“The Panel reminded the program to submit a substantive change request for the entry-level MSN program prior to implementation.”

May 27, 2020 Letter of Decision

“The Panel reminded the program to submit the final CCNE report and CCNE decisions within 30 days of receipt. (WAC 246-840-556).”

May 27, 2020 Letter of Decision

“The Panel reminds the program to submit a substantive change request addressing the planned increase in student numbers as soon as possible and prior to implementation. (WAC 246-840-554).”

Kristen Swanson

April 23, 2021

Page | 2

June 4, 2020

Zoom meeting with Dr. Swanson at her request to review letters of decision from May 27, 2020. Required WAC timelines were reviewed during the discussion.

August 20, 2020 Letter of Decision

“The Panel reminds the program that proposed nursing education program changes must be presented to the commission via a substantive change request for approval at least three months prior to implementation (WAC 246-840-554(3)).”

October

15, 2020 Letter of Decision

The Panel noted the Adult Gero Acute Care NP program track had not been approved and requested the program submit a SCR for Panel review.

“The Panel approved the SCR for the DNP Adult Gero Acute Care Nurse Practitioner program track.” The program sent the SCR to CCNE in 2016.

December 18, 2020 Letter of Decision

“Accepted CCNE DNP and Post-Graduate APRN Certificate programs: 1). 2018 CIPR; 2). 2019 CIPR action letter; 3). 2020 CIPR Post-Graduate APRN Certificate program follow-up report; and 4). 2020 CCNE Post-Graduate APRN Certificate program follow-up report accreditation letter.”

The Panel noted documents 1-4 above had not been submitted and requested the program submit for Panel review.

“The Panel reminded the program to submit documents according to the timelines described in WAC 246-840-556.”

“The Panel accepted the CCNE response letter to the Prelicensure Accelerated Master’s Entry (AME) substantive change request. The Panel reminded the program to submit AME follow-up information to NPAP at the time the report is submitted to CCNE.”

January 21, 2021

Letter of Decision

“Accepted baccalaureate and master’s degree programs: 1). 2017 CIPR; and 2). CCNE response letter to 2017 CIPR.”

The Panel noted documents 1 and 2 above had not been submitted and requested the program submit for Panel review.

April 15, 2021

The Panel noted no CCNE follow-up letter had been received addressing the AME program proposal. The Panel inquired if the program had received a CCNE follow-up letter addressing the AME program proposal.

The program submitted to the Panel the CCNE follow up letter addressing the AME program per Panel request April 8, 2021. The CCNE follow-up letter was dated February 10, 2021.

Kristen Swanson April 23, 2021

WACs 246-840-554 and 246-840-556 contain mandatory obligations with specific timelines for document submission. The nursing program has repeatedly submitted documents outside the required timelines despite regular Panel reminders and requests.

The Panel expressed concern regarding the pattern of non-compliance by the nursing program despite multiple verbal and written reminders and requests. The Panel encourages the program to review WACs 246-840-554 and 246-840-556 and to submit future documents in accordance with WAC timelines. Continued violations of these mandatory requirements are actionable up to and including changes to the approval status of the nursing program. (See WAC 246-840-556(1)(d), 246-840558(4)(c), (4)(e)).

If you have any questions, please contact Dr. Gerianne Babbo at 360-791-4607 or by email at gerianne.babbo@doh.wa.gov, or Dr. Sarah Bear at 360-489-5693 or by email at sarah.bear@doh.wa.gov.

Sincerely, Gerianne Babbo Ed.D, MN, RN Director, Nursing Education Nursing Care Quality Assurance Commission Washington State Department of Health

cc: President Provost

STATE OF WASHINGTON DEPARTMENT OF HEALTH

NursingCare QualityAssurance CommissionPO Box 47864 Olympia,Washington 98504 7864

May 26, 2021

Kristen Swanson, RN, PhD, FAAN, Dean and Professor Seattle University College of Nursing P.O. Box 222000 Seattle, WA 98122-1090

RE: Washington State Nursing Care Quality Assurance Commission Investigation File 20214801TG Seattle University

Dr. Swanson:

As you are aware per our previous correspondence, the Washington State Nursing Care Quality Assurance Commission (NCQAC) received a complaint alleging potential violations of nursing education rules. The investigation now requires a written response from a representative of Seattle University College of Nursing (SUCON) addressing the allegations.

The Washington State Nursing Commission is the agency within state government with legislated authority and responsibility to assure the delivery of safe nursing care, which includes the approval and regulation of nursing education programs. Under the provisions of RCW 18.79.110 and WAC 246-840-558, the Nursing Commission is empowered to investigate complaints against a nursing education program to determine whether the allegations are substantiated.

Allegation:

In 2020 and 2021, Seattle University College of Nursing offered a Master of Science in Nursing (MSN) degree that was neither accredited through the accrediting body (Commission on Collegiate Nursing Education [CCNE]) nor approved by NCQAC.

Allegation specifics include:

1. The unapproved/unaccredited MSN degree offer impacted two cohorts within SUCON’s Advanced Practice Nursing Immersion to Doctor of Nursing Practice (APNI to DNP) program (the 2023 cohort and 2024 cohort).

Public Health – AlwaysWorkingforaSaferandHealthierWashington

2. None of the students within the 2023 and 2024 cohorts, although they completed the required courses and paid the required tuition, are eligible for the award of an MSN degree.

3. 2024 Cohort Specifics:

a. SUCON marketed, advertised, recruited, and enrolled prospective APNI to DNP 2024 cohort students through the offer of an unapproved/unaccredited MSN degree utilizing SUCON’s website and via other electronic/written/verbal communications.

i. The communications noted, in part, that the APNI to DNP program would result in the award of an MSN degree after successful completion of the program’s first year.

b. SUCON enrolled and accepted tuition from the 2024 cohort for a program that marketed the award of both an MSN degree and DNP degree.

c. SUCON did not inform students they would not receive an MSN degree until 03/01/2021, the fourth quarter of their initial year (what SUCON referenced as the “APNI/MSN Year”).

d. SUCON denied student requests for refunds related to the additional MSN credit requirements and curriculum changes after the students’ enrollment, course completion, and notification they would not receive an MSN.

i. SUCON, in written communications to these students, noted in part: “Because we have not yet received and may never receive NCQAC approval of the MSN prelicensure program of study, the College of Nursing has never promised, guaranteed, or agreed that completing any specific or additional courses would result in an MSN degree. As such, the college did not “breach” a promise or contract with you.”

e. Examples of documents provided by SUCON to 2024 cohort students from the students’ initial program enrollment include, in part, the following annotations:

i. The “APNI/MSN Year” tuition is $59,285.00.

ii. An “Overview of the SUCON Entry Level APNI/MSN Program” noting that four of the 20 APNI/MSN courses “may be applied toward the DNP degree”.

iii. A 04/21/2020 letter to the incoming 2024 cohort from SUCON referencing the MSN degree, without noting the degree was neither accredited nor state approved.

iv. Syllabi which note the “lowest passing grades for MSN entry level courses”.

v. Changes to the original 2024 cohort curriculum based on the award of the MSN degree.

vi. Email communications from a SUCON academic advisor noting the “5 quarter MSN granting program” and related curriculum change.

4. 2023 Cohort Specifics:

a. Examples of documents provided by SUCON to 2023 cohort students annotating the MSN include, in part, the following:

i. In a 05/04/2020 letter, SUCON notified the 2023 cohort of their eligibility to receive an award of an MSN degree and noted in part: “Thus, when you complete the 4 DNP courses that are included in the new

entry level MSN, you will be eligible to be awarded an MSN degree.”

ii. A 2020-2021 curriculum summary noted in part:

• “Apply for MSN graduation by Oct 1”

• “Upon completion of NURS 6014, MSN will be awarded”

iii. In a 03/15/2021 letter, SUCON notified both cohorts they would not receive an MSN.

1. The letter included a “Timeline of Events” from 01/201902/2021 wherein SUCON detailed their attempts to obtain NCQAC and CCNE approval of the MSN.

a. The timeline’s events occurred during the same timeframe SUCON actively offered the award of an MSN degree to students.

iv. SUCON initially denied a 2023 cohort student’s refund request. However, after the student complained to the Washington State Achievement Council, SUCON subsequently offered to pay for the student’s NCLEX exam fees, registration fees, an NCLEX review course, and two program courses (NURS 6020 and NURS 6014) [Email, Dean Swanson, 04/12/2021].

v. Multiple curriculum changes throughout the 2019-2020 year referenced the “MSN program revision”.

vi. 2023 cohort students’ SUCON transcripts provided to DOH for RN licensure annotate “Ugrd Nurse Prog Rqmts Complete” [undergraduate]. However, SUCON instructed students to utilize an MSN program code, identify as RN-MSN students, and note their MSN graduation date as 06/12/2020.

Required Response:

1. Please provide a detailed response to each of the allegations as annotated above.

2. Please identify and describe corrective actions, if any, provided by SUCON to 2023 and 2024 cohort students related to the allegations as annotated above.

a. Please identify whether the corrective actions, if any, applied to the cohorts in their entirety or only specific students and the reason(s).

b. Please identify any internal corrective actions within SUCON.

3. Please describe any communications and/or resulting actions between SUCON and the Graduate Student Council related to the allegations as annotated above.

4. A 05/27/2020 Letter of Decision from NCQAC to Dean Kristen Swanson, RN, PhD, FAAN, requested “information posted on the program website regarding nursing programs not having NPAP approval should include the statement ‘pending NCQAC approval’.” (WAC 246-840-512[3]).

a. Please identify changes, if any, to SUCON’s website regarding MSN degree/program annotations after 05/27/2020.

b. Please identify the dates of the changes.

5. A 05/27/2020 Letter of Decision from NCQAC to Dean Swanson requested “Remove ‘End of MSN Pre-Licensure Year’ from the syllabus [NURS 5051] because the entry level MSN has not been approved by the Commission…”.

a. Please identify changes, if any, to SUCON’s APNI to DNP first year syllabi

regarding MSN notations after 05/27/2020.

6. Please detail if SUCON has been contacted by any other regulatory entities regarding any of the allegations as annotated above.

Please provide copies of the following records:

1. Copies of Seattle University College of Nursing archived graduate catalogs (all editions): a. 2018-2019 b. 2019-2020 c. 2020-2021

2. Identification of all SUCON students enrolled or previously enrolled in the APNI to DNP 2023 and 2024 cohorts. Identification will include:

a. Student name b. Date of birth c. Cohort year

d. Date of enrollment and, if applicable, date of disenrollment or date of the initiation of a leave of absence e. Email address

Please ensure the written response is returned to the undersigned no later than June 14, 2021. After that date, the file will be forwarded to the Nursing Commission for review. The preferred means of delivery for all written correspondence is via email. However, the response may also be submitted via mail or fax to the address below.

Please note this is a preliminary investigation and no charges have been issued in connection with this investigation.

If you have any questions, please feel free to contact me at the address or phone number below. Thank you for your cooperation.

Sincerely, Erin Bush Health Care Investigator Nursing Care Quality Assurance Commission P.O. Box 47864 Olympia, WA 98504-7864 erin.bush@doh.wa.gov 360-819-3552 (cell) 360-236-3204 (fax)

Public Health – AlwaysWorkingforaSaferandHealthierWashington

WASHINGTON STATE DEPARTMENT OF HEALTH NURSING CARE QUALITY ASSURANCE COMMISSION

CONFIDENTIAL INVESTIGATION REPORT

************

CASE # 2021-4801TG, 2021-12102TG

RESPONDENT: Seattle University ************

TABLE OF CONTENTS

APPENDIX A – PRINCIPAL PARTICIPANTS

APPENDIX B – GENERAL SUMMARY

APPENDIX C – EVIDENCE/EXHIBITS

APPENDIX D – CONTACT LIST

APPENDIX E – PREVIOUS CASES

APPROVED BY: /s/Lynn Batchelder

Erin Bush Health Care Investigator Phone number: 360-819-3552

DATE: October 14, 2021

APPENDIX A

PRINCIPAL PARTICIPANTS

Respondent Name: Seattle University College of Nursing Address: PO Box 222000 Seattle, WA 98122-4411 Telephone: 206-296-5660 Website: https://www.seattleu.edu/nursing/

License number: TRNG.TG.60968174-DNP First issue date: 05/20/2019 Expiration date: Expired 12/31/2020

Additional Credentials: Reference ILRS

Respondent Attorney: Jordan Talge, Associate University Counsel Seattle University 901 12th Avenue Seattle, WA 98122-1090 Direct: (206) 296-2077 Fax: (206) 296-2664 talgej@seattleu.edu

Complainant: Complainant #1: Stephanie Nicole Lopez Complainant #2: Shelby Elizabeth Stephens

Case #2021-4801TG, 2021-12102TG / Seattle University Page 2 of 13 pages

APPENDIX B

GENERAL SUMMARY

Summary

Seattle College of Nursing (SUCON) allegedly offered an unapproved Master of Science in Nursing (MSN) degree to students enrolled in the Advanced Practice Nursing Immersion to Doctor of Nursing Practice Program (APNI to DNP).

Investigation

Background /Allegation Specifics:

• SUCON’s MSN degree offer impacted the 2023 and 2024 APNI to DNP cohorts.

• SUCON offered the MSN degree without NCQAC approval.

• None of the students within the 2023 and 2024 APNI to DNP cohorts, although they completed the required courses and paid the required tuition, were eligible for the award of an MSN degree.

2024 Cohort Specifics:

• SUCON marketed, advertised, recruited, and enrolled prospective APNI to DNP 2024 cohort students through the offer of an unapproved MSN degree utilizing SUCON’s website and via other electronic/written/verbal communications (pages 3-6, 8-9, 18-20, 28-30, 43-49, 56-57, 60-71, 100, 105, 107-109, 111, 120, 148, 167-170, 345-346, 603, 620-621, 804)

o The communications noted, in part, that the APNI to DNP program would result in the award of an MSN degree after successful completion of the program’s first year.

• SUCON accepted tuition from the 2024 cohort for a program that marketed the award of both an unapproved MSN degree and an approved DNP degree (pages 5, 24-25, 76-81, 107, 336-340, 345-346).

• SUCON did not inform students they would not receive an MSN degree until 03/01/2021, the fourth quarter of the 2024 cohort’s initial year (what SUCON referenced as the “APNI/MSN Year”).

o 03/01/2021 Zoom Meeting Notification 

Transcript of Zoom Meeting (pages 917-932) 

Full Video of Zoom Meeting (page 955 [File 2 of 2])

o 03/15/2021 Letter to Students (pages 38-41)

• SUCON denied student requests for refunds related to the additional MSN credit requirements and curriculum changes after the students’ enrollment, course completion, and notification they would not receive an MSN (pages 54, 120-121)

o SUCON, in written communications to these students, noted in part: “Because we have not yet received and may never receive NCQAC approval of the MSN prelicensure program of study, the College of Nursing has never promised, guaranteed, or agreed that completing any specific or additional courses would result in an MSN degree. As such, the college did not “breach” a promise or contract with you.” (pages 54, 121)

Case #2021-4801TG, 2021-12102TG / Seattle University Page 3 of 13 pages

• Examples of documents provided by SUCON to 2024 cohort students from the students’ initial program enrollment include, in part, the following annotations:

o The “APNI/MSN Year” tuition is $59,285.00 (page 9). 

Estimated tuition: $69,443.00 (page 8)

o An “Overview of the SUCON Entry Level APNI/MSN Program” noting that four of the 20 APNI/MSN courses “may be applied toward the DNP degree” (page 18)

o A 04/21/2020 letter to the incoming 2024 cohort from SUCON referencing the MSN degree, without noting the degree lacked NCQAC approval (pages 19-21)

o Syllabi which noted the “lowest passing grades for MSN entry level courses” (page 148).

2023 Cohort Specifics:

• Examples of documents provided by SUCON to 2023 cohort students annotating the MSN include, in part, the following:

o In a 05/04/2020 letter, SUCON notified the 2023 cohort of their eligibility to receive an award of an MSN degree and noted in part: “Thus, when you complete the 4 DNP courses that are included in the new entry level MSN, you will be eligible to be awarded an MSN degree.” (pages 49, 804) 

Transcripts indicated this event occurred during the fourth quarter of the 2023 cohort’s first academic year (page 82)

o A 2020-2021 curriculum summary noted in part (page 47): 

“Apply for MSN graduation by Oct 1” 

“Upon completion of NURS 6014, MSN will be awarded”

o In a 03/15/2021 letter, SUCON notified both cohorts they would not receive an MSN (pages 50-53). 

The letter included a “Timeline of Events” from 01/2019- 02/2021 wherein SUCON detailed their attempts to obtain NCQAC approval of the MSN (pages 53).

o SUCON initially denied a 2023 cohort student’s refund request (page 54) However, after the student complained to the Washington State Achievement Council (pages 45-46, 607-608), SUCON subsequently offered to pay for the student’s NCLEX exam fees, registration fees, an NCLEX review course, and two program courses (NURS 6020 and NURS 6014) (pages 55-58).

o Multiple curriculum changes throughout the 2020-2021 year referenced the “MSN program revision” (pages 60-71).

o 2023 cohort students’ SUCON transcripts provided to DOH for RN licensure annotate “Ugrd Nurse Prog Rqmts Complete” [undergraduate] (page 88). However, SUCON instructed students to utilize an MSN program code, identify as RN-MSN students, and note their MSN graduation date as 06/12/2020 (pages 692, 822). 

Investigation Notes:

• Reference Complainant 2’s application, NCLEX registration, and ILRS education entry (pages 85, 89, 90)

• 2023 cohort students who indicated they were enrolled in an MSN program on their WA RN License Application responded to a

Case #2021-4801TG, 2021-12102TG / Seattle University Page 4 of 13 pages

Licensed Witness Request Letter summarized later in this report (pages 629-914)

Complainants:

• Complainant 1, 2024 Cohort (pages 2-44)

o Statement to the Washington Student Achievement Council (pages 3-6)

WSAC forwarded the email to NCQAC (page 2)

o Statement to Department of Education (pages 28-29)

• Complainant 2, 2023 Cohort (pages 45-98) o Statement to WSAC (pages 45-46)

WSAC forwarded the email to NCQAC (page 45).

o SUCON denial of refunds/compensation (page 54) o SUCON reversal of denial subsequent to WSAC involvement (pages 55-58, 607608)

Students, Other:

• 2024 Cohort

o Erica Quintana (pages 101-159)

Statement to NCQAC (pages 107-109)

SUCON denial of refunds/compensation (pages 120-121)

o Daniel Tamayo, Assembly Representative / Graduate Student Council (GSC)

GSC Request for Action, Draft (page 167)

GSC Resolution, Draft (pages 168-169)

*Reference investigation note below

o Rachel Valenzuela Ours (pages 170-177)

Memorandum to File, phone interview (pages 170-171)

*Reference investigation note below

Investigation Notes, Student Participation in Investigation:

• Several students expressed concerns regarding anonymity, potential APNI program impacts, and fear of retaliation/retribution for investigation participation.

• NCQAC received an anonymous letter during this investigation which alleged SUCON offered incentives to students to not cooperate with this investigation (pages 99-100).

• Specific student participation details are as follows:

o 05/03/2021: Respondent Notification Letter sent to SUCON by NCQAC (page 178)

o 05/06/2021-05/13/2021: Emails and phone call with Rachel Valenzuela Ours, 2024 Cohort (pages 170-177)

Valenzuela expressed interest in investigation participation (pages 170171, 174).

During a 05/13/2021 phone call with this investigator, Valenzuela-Ours offered to provide a written statement detailing information provided in the call (pages 170-171)

Case #2021-4801TG, 2021-12102TG / Seattle University Page 5 of 13 pages





Tamayo noted he would provide the finalized resolution following a 05/21/2021 council meeting (page 160)

Subsequent attempts to contact Tamayo via phone and email after 05/13/2021 met with negative results (pages 160, 165).

o 05/12/2021: Notice of Representation from SUCON attorney (page 181)

o 05/24/2021: Licensed Witness Request Letter sent to all 2023 cohort members who indicated they were in an MSN program on their WA RN licensure application (pages 629-630).



Note: 2024 cohort students were not eligible to apply for RN licensure until they neared completion of their first APNI year in 07/2021; thus, the Licensed Witness Request Letter was not sent to 2024 cohort students.



Most 2023 cohort student statements indicated similar information in their responses to the Licensed Witness Request Letter (pages 631-914) Note: Reference case file bookmarks for individual students by name.



Many expressed frustrations with NCQAC’s MSN disapproval (or “denial”), rather than SUCON’s MSN offer.



In part, several students detailed concerns and/or provided additional clarification:

• Freyfogle, Anna (pages 666-668)

• Funston, Emilie (pages 672-675) o Impact (page 673)

• Hentges, Taylor (pages 690-694)

• Hutton, Sydney (pages 698-700)

• Le Vasseur, Wilfred (pages 701-704)

• Maierhofer, Ella Rae (pages 619-721)

• Mercado, Elaiza (pages 725-733)

• Olin, Jocelin (pages 736-741)

• Oliver, Isla (pages 742-752)

• Pile, Sadie (pages 755-758)

• Raether, Ethan (pages 759-762)

• Sanchez, Vivianne (pages 767-769)

• Schuster, Jessica (pages 782-784)

• Valdes, Victoria (pages 912-914)

• Walker, Laura (pages 795-796)

//End of Investigation Notes, Student Participation in Investigation//

NPAP (pages 584-606):

• NPAP Communication Timeline with SUCON [produced by NPAP] (page 587)

• Letters of Decision 05/27/2020-04/16/2021 (pages 590-606)

o 05/27/2020 (2) Letter of Decision noting in part (pages 603-604): 

“The Panel requests information posted on the program website regarding nursing programs not having NPAP approval, to include the statement ‘pending NCQAC approval’. (WAC 246-840-512(3)).”

Case #2021-4801TG, 2021-12102TG / Seattle University Page 7 of 13 pages



Investigation Note: Reference screenshot of archived SUCON catalog webpage [no date available; obtained via http://web.archive.org/] (pages 620-621).

• Letter of Concern 04/23/2021 (pages 584-586)

• Email, Dean and NPAP 05/20/2021-05/21/2021 (pages 588-589)

Licensing:

• Certificate of Completion, 2023 Cohort (pages 613-616)

• Certificate of Completion, 2024 Cohort (pages 617-619)

o Investigation Note: Yellow highlights present upon receipt of document.

WSAC (pages 607-610):

• WSAC Letter to SUCON 03/24/2021: Notification of complaint; request for follow-up (pages 607-608)

• WSAC / Investigator Email: Follow-up (pages 609-610)

• Investigation Note: As of a 09/16/2021 phone conference with this investigator, WSAC’s internal determination and/or potential resolution of the student’s complaints is pending.

o WSAC noted, in part:  WSAC does not exercise regulatory authority over private secondary educational institutions; however, WSAC is still considering additional engagement in advocacy efforts between the students and SUCON.

Federal Regulatory Entity Involvement (pages 933-935):

• United States Department of Education, School Eligibility and Oversight Service Group (page 935)

o The agency reviewed SUCON’s use of Title IV funds for the APNI to DNP program.

o The agency determined SUCON appropriately utilized Title IV funding for students enrolled in SUCON’s state approved APNI to DNP program.

Commission on Collegiate Nursing Education (CCNE) (pages 622-627, 915-916):

• SUCON AME (Accelerated Master’s Entry) Correspondence:

o CCNE response to SUCON 10/27/2020 (pages 623-624)

Additional information required

o CCNE response to SUCON 02/10/2021 (pages 625-626)

Additional information required

o Email from SUCON to NCQAC 04/08/2021 (page 627):

Intent to discontinue pursuit of AME program approval/accreditation

Launch plan to instead offer a BSN to APNI students after five quarters of accelerated study based on BSN essentials

Formally close the traditional MSN track program

o CCNE letter to U.S. Department of Education 05/19/2021 (page 622)

Withdrawal of accreditation for SUCON’s traditional MSN program 03/23/2020

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o Current SUCON accredited programs: BSN, DNP, Post-Graduate ARNP Certificate Program [via CCNE website] (page 916)

SUCON Response:

• SUCON provided a response (pages 195-583) to the Letter of Allegation (pages 190193).

• Documents included:

o Statement (pages 342-350)

o Exhibit 1: Substantive Change Notifications (1-4) (pages 351-356)

o Exhibit 2: 08/2020 Emails, Swanson and CCNE (pages 357-364)

Investigation Note: Reference additional CCNE documentation obtained during course of this investigation and previously summarized above (pages 622-627, 915-916).

o Exhibit 3: 05/2021 Emails, NCQAC and Swanson (pages 365-367)

o Exhibit 4: Graduate Curriculum and Evaluation Committee (GCEC)

2021 (pages 368-379)

2020 (pages 380-396)

2019 (pages 397-414)

o Exhibit 5: Summer 2020 DNP Newsletter (pages 416-424)

Message from Swanson (page 416)

Investigation Note: In their response, SUCON noted a Graduate Student Council (GSC) did not exist at the college (page 348). However, the 2020 DNP Newsletter contained a header for the “Graduate Student Council” (page 422) with a post related to appropriate student signature blocks in emails (page 423). Reference GSC documents provided by student Daniel Tamayo as previously summarized above (pages 160-169).

o Exhibit 6: APNI Syllabi Folder / Substantive Change AME (pages 425-583)

• Documents submitted by SUCON prior to delivery of statement (pages 195-340):

o SUCON Catalogs:

2018-2019 (pages 196-243)

2019-2020 (pages 244-292)

2020-2021 (pages 293-333)

o Enrollment Records

2023 Cohort Student Roster (pages 334-336)

2024 Cohort Student Roster (pages 336-340)

Investigation Note: SUCON’s attorney summarized a phone call with this investigator (pages 187-188). This investigator did not state that NCQAC does not have written rules or procedures for governing investigations, as noted by the SUCON attorney (page 187). //End of General Summary//

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APPENDIX C

EVIDENCE/EXHIBITS

Page #’s Description

FILE 1 OF 2

Confidentiality Notice 2-44 Complainant 1, 2024 45-98 Complainant 2, 2023 99-100 Anonymous Statement 101-159 Erica Quitana, 2024 160-169 Daniel Tamayo, 2024 170-177 Rachel Valenzuela-Ours, 2024 178 Respondent Notification Letter 179-583 Respondent Documentation 584-606 NPAP / SUCON Documentation 607-610 WSAC Documentation 611-619 CoC’s, 2023 and 2024 620-621 SUCON Web Screenshot 622-627 CCNE Documentation 628-914 2023 Cohort Correspondence 915-916 CCNE Web Screenshots 917-932 Zoom Transcript 933-935 Emails, Federal Entities 936-937 Text Message Screenshots

1

FILE 2 OF 2 938-955 Zoom Transcript and Video

Case #2021-4801TG, 2021-12102TG / Seattle University Page 10 of 13 pages

APPENDIX D

CONTACT LIST (Other than principals)

Erin Bush, Healthcare Investigator Department of Health Nursing Care Quality Assurance Commission PO Box 47864 Olympia, WA 98504-7864 360-819-3552 erin.bush@doh.wa.gov

Kristen Swanson, RN, PhD, FAAN, Dean and Professor Seattle University College of Nursing PO Box 222000 Seattle, WA 98122-4411 (206) 296-5670 swansonk@seattleu.edu

Bonnie H. Bowie, PhD, MBA, RN, FAAN, Associate Dean and Professor Seattle University College of Nursing 901 12th Ave PO Box 222000 Seattle, WA 98122-4411 (206) 398-4371 bowieb@seattleu.edu

Sam Loftin, J.D. Director of Consumer Protection Washington Student Achievement Council 360-485-1078 SamL@wsac.wa.gov

Marisol Mendoza

United States Department of Education School Eligibility and Oversight Service Group San Francisco Seattle School Participation Division 50 United Nations Plaza – Mailbox 1200 – Room 1273 San Francisco, CA 94102 Marisol.Mendoza@ed.gov

Michael P. Meotti Executive Director Washington Student Achievement Council

Case #2021-4801TG, 2021-12102TG / Seattle University Page 11 of 13 pages

360-485-1074

MichaelM@wsac.wa.gov

Adam M. Shanedling Special Agent in Charge

U.S. Department of Education Office of Inspector General One World Trade Center, Suite 2300 Long Beach, CA 90831

Direct: (562) 980-4136 Fax: (562) 980-4143 Adam.Shanedling@ed.gov

**2023 and 2024 cohort student contact information can be accessed via ILRS**

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APPENDIX E

PREVIOUS CASES

None listed in ILRS

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STATE OF WASHINGTON DEPARTMENT OF HEALTH Nursing Care Quality Assurance Commission PO Box 47864 Olympia, WA 98504 7864

November 22, 2021

Kristen Swanson, RN, PhD, FAAN Dean and Professor

Seattle University College of Nursing P.O. Box 222000 Seattle, WA 98122 1090

Letter of Decision: Accepted NCQAC Complaint Investigation report; Determined violations of WAC 246840-512(3) and WAC 246-840-516(6) occurred; Closed complaint as violations were resolved.

Dear Dr. Swanson:

The Washington State Nursing Care Quality Assurance Commission Nursing Program Approval Panel (Panel) met on November 18, 2021 to review Seattle University’s NCQAC Complaint Investigation Report. The Panel accepted the NCQAC Complaint Investigation report.

The Panel determined violation of WAC 246 840 512(3) occurred: (3) Program information communicated by the nursing education program must be accurate, complete, and consistent.

The Panel determined violation of WAC 246 840 516(6) occurred: (6) The nursing education program shall provide accurate information to students and the public.

Misleading and inaccurate information was provided to students and the public through the college of nursing website, emails and letters to students, syllabi, the 2020-21 college catalog, and transcript of the APNI Year All cohort Zoom meeting held Monday, March 1, 2021.

Although violations were founded, the Panel also determined that the violations have been corrected, and therefore declined to take further action at this time and closed the case.

If you have any questions, please contact Dr. Gerianne Babbo at 360 791 4607 or by email at gerianne.babbo@doh.wa.gov, or Dr. Sarah Bear at 360-489-5693 or by email at sarah.bear@doh.wa.gov

Sincerely,

Gerianne Babbo Ed.D, MN, RN Director, Nursing Education Nursing Care Quality Assurance Commission Washington State Department of Health

cc: President Provost