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State Compliance Guide

Moderate Sedation Requirements in Vermont

The Vermont State Board of Nursing publishes no document about nurse-administered sedation — and that absence is the finding, because it once did. A 2015 capture of the Board’s old index carried eight headings and twenty-nine statements, among them Anesthesia/Analgesia/OR, whose six documents included Role of the Nurse in the Administration and Monitoring of Moderate Sedation and Role of the Nurse in the Administration of Propofol. Twenty-one of those twenty-nine titles are absent from the eight the Board publishes today, so what the archive records is a pruning of the whole shelf, not a retreat from sedation alone. This page builds on the scope-of-practice test Vermont does still publish.

Vermont at a glance

Board Vermont State Board of Nursing, within the Secretary of State’s Office of Professional Regulation. Its practice shelf, enumerated from its own Statutes, Rules & Resources page on 2026-09-02: the Administrative Rules plus eight position-statement PDFs, none about sedation.
Document The Board publishes none on sedation, so this guide is built on the first of those eight: APRN/RN/LPN Scope of Practice Position Statement and Decision Tree, five pages — every page number here refers to it. Supporting, cited by number only: the Administrative Rules (effective May 11, 2023) and 26 V.S.A. ch. 28.
Rule it applies Not itself a rule. It names the Nurse Practice Act, 26 V.S.A. ch. 28, as the legal basis for nursing scope (p. 2) and reproduces the § 1572 licence definitions (pp. 1–2). Rule 11-1 is the binding restatement of its test.
Status Advisory, and it says so of its own tools: the decision tree and comparison chart “are meant to be used as a guides or self help tools and do not constitute legal opinions” (p. 2), reproduced as printed. Its prose is flatter: “A nurse may not perform activities which exceed the scope defined by the individual level of licensure.” (p. 2).
Dates Initial acceptance November 2009; revised September 14, 2015, then July 9, 2018. A third Revised line and the Reviewed line are printed blank (p. 3) — no review recorded since 2018.
Who it covers “Every APRN, RN, and LPN is accountable, both professionally and legally, for determining and practicing within his or her individual scope of practice” (p. 2).
Who it does not cover Not stated as an exclusion; it carves nobody out of sedation practice because sedation is not among the activities it addresses. The line its comparison chart draws is RN versus LPN, and neither column mentions sedation.
Settings the document names Not stated: the words hospital, clinic, office and surgical do not appear in it. Setting enters only as a factor determining scope — “practice setting and population served”, alongside “the availability of appropriate equipment, supervision and support” (p. 2).
Re-verification interval Not stated — not in the statement, not in Rule 11-1. The tree asks for “evidence of your current competency and skill” (p. 4); Rule 11-1(b) requires the same, present-tense, with no period attached.
Where the record lives Not stated. Individual scope “is supported by documented evidence of education and competence in performing nursing activities” (p. 2), but no custodian, format or retention period is named. Rule 11-1(d) does require institutional policies or procedures governing the activity, and consistency with them.
CE hours None sedation-specific, and no contact-hour count for any procedure. Biennial renewal under Rule 4-8(a) is a choice of three routes, paraphrased: practice hours (400 in two years, or 960 in five); 20 hours of qualifying continuing education in the preceding two years; or a current nationally recognized certification. No subject is mandated for RNs or LPNs — Part 1 defines qualifying continuing education by approver, not subject.

What the Vermont State Board of Nursing says

The statement answers one question: how a nurse decides whether an activity is inside their scope, individually rather than by task. Its § 1572 definition of registered nursing sets out fourteen lettered components it is “not limited to” (p. 1), among them “Addressing patient pain” (p. 1) — a statutory description of what registered nursing is, not sedation authority. The operative sentence is the one about evidence:

“Within the parameters outlined by the Vermont Nurse Practice Act, the individual scope of practice for each APRN, RN and LPN is determined by the individual’s education, training, experience, and certification. The individual licensee’s scope of practice is supported by documented evidence of education and competence in performing nursing activities.”

Vermont State Board of Nursing scope-of-practice position statement, p. 2

Read the primary source →

A flow chart puts the same test as eight questions ending at “The activity is within your scope of practice” (p. 4); any no stops it. Paraphrased in order: prohibition by Vermont law or rule; consistency with the Nurse Practice Act, the Board’s position statements, national nursing organization standards of practice, the nursing literature and research, or accreditation standards; completed education and current knowledge to perform it safely; evidence of current competency and skill; the reasonable and prudent nurse with similar training and experience; facility policy and procedure; adequate resources in the care setting to protect patient safety; readiness to accept and manage the consequences. Rule 11-1 restates the same test in binding prose, closing that without any of its conditions the activity would be out of scope for an individual nurse and should not be performed. One seam shows here: the tree sends a nurse to the Board’s position statements, and for sedation there is none to read.

What a Vermont facility should be able to show

Because the Board sets no sedation standard, the measure is your own policy plus whatever your facility’s licensing regulator requires — and the Board’s test makes that policy a condition:

  1. Your own moderate-sedation policy, dated and approved — who may administer, under whose order, what is monitored, what is recorded. The tree asks “Is the activity consistent with facility policy and procedure?” (p. 4); Rule 11-1(d) requires the same, and neither supplies the particulars.
  2. Per-nurse evidence of initial education and training for every RN who administers or monitors moderate sedation — the education and knowledge the tree asks about (p. 4), and Rule 11-1(a).
  3. Per-nurse evidence of ongoing competence, on an interval your own policy names — “evidence of your current competency and skill” (p. 4) and Rule 11-1(b). The Board names no interval for it.

The CSRN™ course — 10 CE contact hours developed and delivered by Capt. M. Ron Eslinger, CRNA, with module exams, case studies and a certificate ID your credentialing office can verify — is built to be records 2 and 3 on that list. Facility seats and roster tracking →

Questions Vermont facilities ask

Does the Vermont Board of Nursing set a renewal interval for sedation competency?

No. The statement does not address sedation, so it sets no interval for it — and none for any other activity either: the tree asks for evidence of current competency in the present tense and stops there, as does Rule 11-1(b). The biennial cycle in Rule 4-8(a) is a licence-renewal requirement, not a competency check for any procedure.

Does Vermont require the CSRN™ course specifically?

No. The statement names no course at all — the word does not appear in it — and no state mandates this specific one. Take care with the word certification: the statement lists it among the four things that determine an individual’s scope (p. 2), but it does not say a certification authorises any activity. What does the work is Rule 11-1(b)’s evidence of current competency and skill — and CSRN™ is designed to be that evidence.

Vermont used to have a moderate sedation position statement. Can we still rely on it?

Not as current Board guidance. The 2015 capture listed the moderate-sedation and propofol titles under an Anesthesia/Analgesia/OR heading; that heading and all six of its documents are absent from the eight statements the Board publishes today. Copies circulate on third-party sites as current Vermont requirements; this page reproduces none of them. If one of your policies cites a Vermont sedation position statement, treat that citation as needing replacement — by the scope test above, your own policy, and your facility licensing requirements.


Compliance note (last reviewed September 2026): This page is educational information about the Board’s APRN/RN/LPN Scope of Practice position statement, not legal advice or a compliance determination. Every quotation was checked word-for-word against that five-page PDF on 2026-09-01, the file the Board links today; it was last revised July 9, 2018. Rule numbers refer to the Administrative Rules effective May 11, 2023, which contain the word sedation nowhere in their 39 pages, and neither does 26 V.S.A. ch. 28. The no-sedation-document finding concerns the Board of Nursing alone, checked against its own list — facility licensing rules and other Vermont regulators were not reviewed here. Confirm the current documents and your own policy before relying on this summary. No state mandates this specific course.

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