Untitled Texas Attorney General Opinion

CWAWFORD c. IMAZCT~N AUSTIN, %-EXAR 78711 AT-rORNEY csEN&RAL September 29, 1970 Honorable Preston Smith Opinion No. M- 699 Governor of Texas Capitol Station Re: Several questions relative Austin, Texas 78711 to licensing of nursing home administrators under Senate Bill 388, Acts 1969, 61st Legislature, chapter 411, page 1356 (codified by Vernon as Article 44428). and a Dear Governor Smith: related question. Your letter of August 17, 1970, states the following facts: "Our office has received correspondence from nursing home administrators who assert that they have been in the nursing home business for many years (several for over twenty years). These ad- ministrators assert that they should be qualified for a license by their training and experience under the provisions of Section 6(l) and Section 9(2) of the Act." Your letter then asks six questions, however, by your subsequent letter of September 10, 1970, you withdrew your request for answer to questions 3, 4 and 5. We therefore direct our attention to questions 1, 2 and 6 stated as follows: "1) Does Section 6(l) and Section 9(2) of Senate Bill 388, 61st Legislature, regular session, 1969, give the Board the authority to establish an educational training requirement exclusive of a con- sideration of the applicant's experience in the field of institutional administration, or is the phrase in -3376- Honorable Preston Smith, page 2 (M-6999 Section 6(l), 'by training or experience in the field of institutional admixstration', and the phrase in Section g(2), "or has presented evi- dence satisfactory to the?;oard of sufficient education, training, or experience...'intended to require the Board to establish standards which consider the experience of an applicant in conjunc- tion with the amount of his formal education training, thus requiring a lesser degree of formal training of an administrator with several years experience in the field of nursing home administration? "2) Does Section 6( 19 and Section 9(2) of Senate Bill 388, 61st Legislature, regular session, 1969, provide that nursing home administrators can qualify for a license without taking the examination and meeting the additional educational requirements if they can prove by documented evidence that a) they are of good moral character, b) they have sufficient training or experience, and c) they have been in the past and presently are qualified to serve as nursing home administrators, i.e. is Section 6(l) and Section 9(2) intended to be a "grandfather clause'? "69 Does this Board have the authority to retain and employ private counsel to initiate suit against violators of this Act when Section 15 of the Act specifically provides that the Attorney General will render such legal assistance as may be neces- sary to enforce and make effective the Act?"' Inasmuch as questions 1 and 2 each require several separate answers, we will break them down for convenience. The first part of question 1 asks whether the Board can establish a licensing requirement in addition to a consideration of an applicant's experience as set out in Section 6(l) and Section 9(2) of the Act. We answer "no"'to this part of question No. 1. -3317- . Honorable Preston Smith, page 3 (M-699) Section 6(l) reads as follows: "(1) develop, impose, and enforce standards which must be met by individuals in or,der to re- ceive a license as a nursing home administrator, which standards shall be designed to insure that nursing home administrators will be individuals who are of good character and are otherwise suitable, and who, by training or experience in the field of institutional administration, are qualified to serve as nursing home administrators:" (Emphasis added.) Section 9 prescribes all the necessary qualifications of an applicant for nursing home administrator license. Section 9(2) reads as follows: "Section 9(2) ... he,has satisfactorily com- pleted a course of instruction and training pre- scribed by the board, which course of instruction shall be designed aa to content and so administered as to present sufficient knowledge of the proper needs to be served by nursing homes; laws gwern- ing the operation of nursing homes and the pro- tection of the interests of patients therein; and the elements of good nursing home administration: z has presented evidence satisfactory to the board of sufficient education, training, z experience in the foregoing fields to enable him to administer, supervise and manage a nursing home." (Emphasis added.) Both section 6(l) and 9(2) of the Act are stated in the disjunctive by use of the word "or" allowing the applicant the benefit of the use of prior expexence to fulfill this por- tion of his qualification, subject to such experience being satisfactory to the board which has exclusive jurisdiction to determine each applicant's "... qualification, skill and fitness ...W under Section 5 of the Act. -3378- . . Honorable Preston Smith, page 4 (M-699) By the above holding, we answer the last part of question 1, "yes". We believe that it was the intention of the Legislature, by the disjunctive language in Section 6(l) and 9(2), to require the Board to consider the experience of an ap- plicant along with his formal training wherein it is stated in part in Section 9(2) as follows: II .. . or has presented evidence satisfactory to the board of sufficient education, traininq, or exverience..." (Emphasis added.) The first part of ycur second question asks whether Section 6(l) and 9(2) allow an applicant for licensure to sub- stitute good moral character, training or experience, or quali- fication to presently serve as nursing home administrator, for the examination. We answer this portion of your second question "no" . Section 9 of the Act lists the requirements for the is- suance of a license: and while there are some alternatives or choices in Section 9, there is no alternative requirement for the examination and it must be taken by all parties who wish to be licensed as a nursing home administrator. This require- ment is set out in Section 9(3) as follows: "3) he has passed an examination administered by the board designed to test for competence in the subject matters referred to in subsection (2) hereof:" We deem it necessary to observe, however, that the statute does not prescribe the extent of detail of this exam- ination. This was a matter left within the sound discretion of the Board, which may use any reasonable means as it may de- termine necessary to satisfy itself that the applicant possesses sufficient education, training, or experience. The Board may make reasonable classifications among applicants, based upon the number of years of experience and training, and they may administer a more extensive or different kind of test for ap- plicants without any substantial experience, education, or training than to those possessing a number of years of such experience, training, or education. However, we cannot conclude -3379- . . Honorable Preston Smith; page 5 (M-6991 that the Board has the authority to waive the examination for a certain class of applicants with substantial experience, training, or education. The statute expressly directs that, “No license shall be issued to a person ... unless . ..(3) he has passed an examination administered by the board and de- signed to test for competence . ..I' There are no exceptions to this requirement and no authority given to waive an examination. The next part of your second question asks whether an applicant can qualify for a license under the Act by substituting, with documented evidence, 'proof.of good moral character, suf- ficient training or experience.and the fact that the applicant in the past and present are qual'ified 'to serve as nursing home administrator, for educational requirements. We answer this part of your question "yes". An applicant must (1) have grad- uated from an approved high school or secondarv school or have a certified equivalency certificate (Sectiong(4 ): (29 passed an examination on the subject matter of Section g(2): and (3) have completed the course of training and instruction pre- scribed by ths board 'I...z has presented evidence satisfactory to the board of sufficient education, training, or experience in the foregoing fields to enable him to administer, supervise, and manage a nursing home" Section 9(2) of the Act. Further, we do not believe that Sections 6(l) and 9(2) were intended to be grandfather clauses in the true sense of that term. While these sections do allow those previously employed as nursing home administrators a substitution of ex- perience for course work, applicants are not automatically granted a license based on prior experience or training and are required, as all applicants to pass an examination (Section LJ(!?) and have the basic education required pursuant to Section g(4). You are accordingly advised that under the facts sub- mitted, individuals possessing the qualifications described in your letter would be entitled to receive a license assuming that such individuals also comp'ly'with the provisions of subdivisions (l), (39 and (4) of Section 9. We recognize,that subdivision (5) of this Section requires an applicant to comply with all other qualifications and requirementsas may have been established by -3380- . Honorable Preston Smith, page 6 (M-699) rule or regulation of the Board. In this instance, it is our opinion that the Board may not establish a rule or regulation contrary to the express provisions of subdivision (2) of Section 9. Our opinion is not to be construed as in any manner infringing upon the discretion to be exercised by the Board under the statutory enactment. It is the Board's exclusive authority to make the determination in each case whether an applicant has furnished satisfactory evidence that he possesses the experience as a nursing home administrator as specified in subdivision (2) of Section 9, and such determination will not be overturned except in those instances where the Board's find- ing is not supported by substantial evidence. In answer to your 6th question it is noted that Section 15 of the Act provides: "Sec. 15. The Attorney General is directed to render such legal assistance as may be neces- sary in enforcing and making effective the pro- visions of this Act, provided that this require- ment shall not relieve the local prosecuting of- ficers of any of their duties under the law as such." In view of the foregoing, it is wr opinion that the Attorney General, district attorneys and county attorneys are the only legal representatives of the Board authorized to in- stitute suits against violators of this Act. SUMMARY Under Article 4442d, Section 6(l) and 9(2) the Texas Board of Licensure for Nursing Home Administrators is not authorized to establish an educational training requirement in addition to a consideration of applicant's experience and who is found by the Board to possess sufficient experience in the field of nursing home administration. -3381- . . Honorable Preston Sinith, page 7 :' (M-699) Section 6(l) and 9(2) of Article 4442d re- quire the Board to establish standards which con- sider an applicant's experience and training in the field of nursing home administration. All applicants must pass an examination ad- ministered by the board before a nursing home ad- ministrator's license may be issued. An applicant may submit evidence, satisfactory to the board, of education, training or experience in the fields set out in Section 9(2) of Article 44426 as a substitute for the course of instruction and training prescribed by the board. Section 6(l) and 9(2) of Article 4442d are not grandfather clauses in the true sense of the term. Section 15 of Article 4442d provides the only authority for the board's legal representa- tion, that being by the Attorney General and "local prosecuting officers". Ve lzg&QzC . TIN General of Texas Prepared by Melvin E. Corley Assistant Attorney General -3382- -’ . Honorable Preston Smith, page 8 (M-699) APPROVED, OPINION COMMITTEE Kerns Taylor, Chairman W. E. Allen, Co-Chairman James Quick Harriet Burke Charles Parrett Wayne R. Rodgers MEADE F. GRIFFIN Staff Legal Assistant ALFRED WALKER Executive Assistant NOLA WHITE First Assistant -3383-