Such contracts included arbitration clauses with class action waivers. The Florida Supreme Court disagreed and determined that all claims could only move forward through individual arbitrations. Clemins v. GE Money Bank, No. After enrolling, one plaintiff claims that she learned she was ineligible because shereceived disability benefits; and the other claims that she was enrolled and charged without her consent, and that she only learned she was ineligible because she was self-employed when she applied for relief.
They brought claims alleging that GE Money Bank breached their credit card agreements and the agreements governing the debt cancellation program — as well as unjust enrichment claims. However, the credit card contracts contained forced arbitration clauses with class action waivers. The court found the arbitration agreements binding and dismissed the case. Safadi v. Citibank, N. However, the court found that the arbitration agreement was valid and dismissed thecase.
Orman v. Citigroup, Inc. Villano v. TD Bank, No. Ultimately the plaintiffs closed their franchise because of poor financial results. They were able to repay their loan, but had to use their personal savings. The agreement that they signed with Matco contained an arbitration clause as well as a forum selection clause — which stated that all arbitration hearings must take place in Summit County, Ohio. The court held that the claims had to be arbitrated as per the agreement.
Garcia v. In October , the customer filed a class action suit against the dealer for sending prerecorded, unsolicited messages to customer cellphones in violation of the Telephone Consumer Protection Act. The court found that the arbitration provision covered the claims raised and dismissed the lawsuit. Further, it was alleged, the CTIA and the carriers promulgated guidelines to prevent firms or institutions from sending their mass text messages by means of regular ten-digit numbers, and thus forced them to lease from Neustar and pay higher per- message charges to aggregators and carriers.
Plaintiffs did not even sue Neustar. The case was therefore largely dismissed in favor of the arbitration. Shorts v. According to the court, Ms. Shorts reportedly failed to make payments, and eventually her service was terminated and she was charged an early termination fee that she did not pay.
She counterclaimed that the early termination fee and collection attempts violated the West Virginia Consumer Credit and Protection Act.
Riensche v. C, WL W. However, their contracts with Cingular included arbitration provisions.
While an initial motion to compel arbitration was denied and after four years of litigation, the motion was renewed and the court compelled arbitration. Vernon v. Qwest Communications Int'l, Inc. Qwest included an arbitration clause with a class action waiver in their Subscriber Agreement. However, according to the consumers, they did not provide copies of this agreement to their new customers. The consumers said that it was only available if people went searching for it online. Davis v. Sprint Nextel Corp. She brought claims of breach of contract, fraud, unjust enrichment, and violation of the Missouri Merchandising Practices Act.
Baccalaureate education in nursing and patient outcomes. The court agreed. Risk Factors. Hospital nurse practice environments and outcomes for surgical oncology patients. The snow albedo depends on zenith angle, effective grain size, and the presence of aerosols black carbon, organic carbon, and mineral dust deposited from the atmosphere. The Company is focused on expanding its market opportunities related to personal computers and mobile communication and media devices.
However, the Subscriber Agreement included an arbitration clause, which the court found valid and enforceable and dismissed the case. Phillips v. Sprint PCS, Cal.
Schnuerle v. Insight Communications Co. The customers say that Insight did not warn them about the outages and gave misleading, incorrect information when customers called. All Insight service agreements contained forced arbitration clauses and class action bans. The court upheld the arbitration clause and class action ban. It struck down a confidentiality agreement contained within the arbitration clause. Pendergast v.
While the initial service contract did not contain a class action waiver, new terms and conditions were in use when the plaintiff purchased a new phone with Sprint four years later. At that point a class action waiver was included in the arbitration clause. As a result, the court dismissed the case. Flores v. Uber Techs. The company had waited a full year to reveal the data breach, notifying approximately 57 million Uber customers and , drivers in November that their personal identification information had been compromised.
Valve Corp. Legal claims included violations of the Washington Consumer Protection Act and the Washington Gambling Act, unjust enrichment, negligence and declaratory relief. Valve countered that the children had agreed to arbitrate any disputes when they created their accounts and that their parents, though non-signatories, were also bound by those terms. Simpson v. Pulte Home Corp. They additionally brought claims of international misrepresentation, concealment, and negligent misrepresentation.
According to the homebuyers, Plute failed to tell the purchasers the homes they built would be subject to undisclosed taxes, governmental special assessments. They claimed Pulte did this to make their homes appear more valuable than they actually were. However, the homebuyers signed purchase agreements with Pulte that included a forced arbitration clause and class action waiver. The court upheld the clause and dismissed the case.
The Hertz Corp , No. York v. Dodgeland of Columbia, Inc. However, when buying their cars, both Melissa and Olga signed contracts that included arbitration clauses. The court dismissed the lawsuit because of the arbitration clauses. Vasquez v. Greene Motors, Inc. This second contract was executed on February 2, and included different financial terms. However, Vasquez claims Greene Motors backdated the contract, which, according to Vasquez, meant there were different financing terms.
Vasquez brought a case against Greene Motors because of this discrepancy alleging violations of the Rees-Levering Automobile Sales Finance, the Consumers Legal Remedies Act, and the unfair competition law. However, the contract included an arbitration clause. Covina Auto Group, Cal. After buying the car, she says that she experienced numerous problems and took it to Toyota Motor Sales where it was repaired multiple times.
West Covina Toyota filed a motion to compel arbitration based on the sales contract Naasz signed, which included an arbitrationclause with a class action waiver. The court agreed, dismissing the lawsuit and compellingarbitration. Botorff v. Amerco, No. According to Botoroff, no one discussed any of the terms or conditions in the contract with her.
She later filed a complaint, on behalf of herself and others, alleging that U-Haul coerced its competitors to raise rental prices, violating California state law and causing people to overpay for their truck rentals. The court held that even though Botorff had not been given the addendum at the time she signed the rentalcontracts, as long as they were available to her upon request, the arbitration clause was valid and enforceable. Thus the Court dismissed thelawsuit. Sakyi v.
E, Doran, D. Impact of hospital nursing care on day mortality for acute medical patients. Journal of Advanced Nursing , 57 1 , Tri-Council for Nursing. Educational advancement of registered nurses: A consensus position. Yakusheva, O. Medical Care , 52 10 , Last Update: April Robert Rosseter rrosseter aacnnursing. The Impact of Education on Nursing Practice. Download PDF Version The American Association of Colleges of Nursing AACN , the national voice for academic nursing, believes that education has a significant impact on the knowledge and competencies of the nurse clinician, as it does for all healthcare providers.
Different Approaches to Nursing Education. In February , the Campaign for Nursing's Future, an initiative of the Center to Champion Nursing in America, published a series of state maps showcasing the progress being made by nurses in attaining baccalaureate degrees. In December , New York Governor Andrew Cuomo signed legislation into law requiring future registered nurses graduating from associate degree or diploma nursing programs in the state to obtain a baccalaureate in nursing within 10 years of initial licensure.
The study showed that 42 of baccalaureate outcomes were reported met in ADN programs. The 67 outcomes that were not met were in the categories of liberal education, organizational and systems leadership, evidence-based practice, healthcare policy, finance and regulatory environments, interprofessional collaboration, and population health.
Articles focus on the evidence linking better outcomes to baccalaureate and higher degree nurses, educational pathways, and promising strategies for facilitating academic progression at the school, state, and national levels. This historic agreement represents the first time leaders from the major national organizations representing community college presidents, boards, and program administrators have joined with representatives from nursing education associations to promote academic progression in nursing.
With the common goal of preparing a well-educated, diverse nursing workforce, this statement represents the shared view that nursing students and practicing nurses should be supported in their efforts to pursue higher levels of education. Their strong support for high quality baccalaureate degree programs as the appropriate pathway for RNs entering the profession is consistent with the views of many leading nursing organizations, including AACN. In February , the Council on Physician and Nurse Supply released a statement calling for a national effort to substantially expand baccalaureate nursing programs.
In the statement, the Council noted that a growing body of research supports the relationship between the level of nursing education and both the quality and safety of patient care. Consequently, the group is calling on policymakers to shift federal funding priorities in favor of supporting more baccalaureate nursing programs. This call was reaffirmed in a new statement released in March In March , the American Organization of Nurse Executives AONE released a statement calling for all RNs to be educated in baccalaureate programs in an effort to adequately prepare clinicians for their challenging, complex roles.
Nursing Workforce: Trends in Supply and Education. The increased complexity of the scope of practice for RNs requires a workforce that has the capacity to adapt to change. It requires critical thinking and problem solving skills; a sound foundation in a broad range of basic sciences; knowledge of behavioral, social and management sciences; and the ability to analyze and communicate data.
Among the three types of entry-level nursing education programs, NACNEP found that baccalaureate education with its broader and stronger scientific curriculum best fulfills these requirements and provides a sound foundation for addressing the complex health care needs of today in a variety of nursing positions.
Baccalaureate education provides a base from which nurses move into graduate education and advanced nursing roles. There is a growing consensus in the higher education community that a liberal arts education should be embedded in all the professional disciplines. Graduates with a liberal education are prized by employers for their analytical and creative capacities and demonstrate stronger skills in the areas of communication, assessment, cultural sensitivity, resourcefulness, the ability to apply knowledge, and scientific reasoning.
Though some arts and science courses are included in ADN programs, the BSN provides a much stronger base in the humanities and sciences. In addition to hundreds of individual agreements between community colleges and four-year schools, state-wide articulation agreements exist in many areas including Florida, Connecticut, Texas, Iowa, Maryland, South Carolina, Idaho, Alabama, and Nevada to facilitate advancement to the baccalaureate. These programs further validate the unique competencies gained in BSN programs.
These health professionals, including physicians, pharmacists, and speech pathologists, recognize the complexity involved in providing patient care and understand the value and need for higher education. Since nurses are primarily responsible for direct patient care and care coordination, these clinicians should not be the least educated member of the healthcare team. Maya Djukic and her colleagues from New York University released details from a new study, which found that baccalaureate-prepared RNs reported being significantly better prepared than associate degree nurses on 12 out of 16 areas related to quality and safety, including evidence-based practice, data analysis, and project implementation.
The authors conclude that improving accreditation and organizational policies requiring the BSN for RNs could help safeguard the quality of patient care. Linda Aiken and colleagues reported findings from a study of adult acute care hospitals in six European nations, which found that a greater proportion of professional nurses at the bedside is associated with better outcomes for patients and nurses. Reducing nursing skill mix by adding assistive personnel without professional nurse qualifications may contribute to preventable deaths, erode care quality, and contribute to nurse shortages.
These outcomes translate into cost savings that would more than off-set expenses for increasing the number of baccalaureate-prepared nurses in hospital settings.
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In an article published in the March issue of Health Affairs , nurse researcher Ann Kutney-Lee and colleagues found that a point increase in the percentage of nurses holding a BSN within a hospital was associated with an average reduction of 2. The researchers found that hospitals with a higher percentage of RNs with baccalaureate or higher degrees had lower congestive heart failure mortality, decubitus ulcers, failure to rescue, and postoperative deep vein thrombosis or pulmonary embolism and shorter length of stay.
The study authors conclude that these better outcomes were attributed in large part to investments in highly qualified and educated nurses, including a higher proportion of baccalaureate prepared nurses. Deborah Kendall-Gallagher, Linda Aiken, and colleagues released the findings of an extensive study of the impact nurse specialty certification has on lowering patient mortality and failure to rescue rates in hospital settings. The researchers found that certification was associated with better patient outcomes, but only when care was provided by nurses with baccalaureate level education.
Christopher Friese and colleagues found that nursing education level was significantly associated with patient outcomes. Nurses prepared at the baccalaureate-level were linked with lower mortality and failure-to-rescue rates. Linda Aiken and her colleagues confirmed the findings from her landmark study see below which show a strong link between RN education level and patient outcomes.
Led by Dr. Ann E. Tourangeau, researchers from the University of Toronto and the Institute for Clinical Evaluative Sciences in Ontario studied 46, patients admitted to the hospital with heart attacks, strokes, pneumonia and blood poisoning. African-American and Latino children, and children from lower-income households, are more likely to walk or bicycle to school in CA but are less likely to have safe streets on which to travel.
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