On February 21, 2024 a
Exhibit,Appendix
was filed
involving a dispute between
Aderonke Ojerinde,
Alice Kwane Frempong,
Anita Barbara Asamoah,
Awal Mohammad Rahaman,
Bartholomew Ezem,
Beatrice Leste,
Brenda Andrews,
Camille Alexa Joasil,
Celestine Chi Aririguzoh,
Charity Akakpo,
Charyl Pilgrim,
Christian Nwankwo,
Elizabeth King-Nabi,
Emmanuel Tetteh,
Ese Okoko,
Eucharia Nweguah Nasah,
Frances Linda Ojeifo,
Gaytreedebie Boedhai,
Jacqueline Boamah-Bright,
Jennifer Okoro,
Joana Amoafo Dofoo,
Johan Nesbitt,
Johnnet Korvah,
Jolette Pasteur,
Joyce Chambers,
Julene Alexander,
Kadiatu Sei-Bureh,
Karen Saulong,
Keshia Porter,
Lisabeth Johnson,
Louise Gelin,
Mabel Boakye,
Marcus Fairclough,
Maria Sokolo,
Mark Gyau,
Miatta Soko,
Micaela Haywood,
Mike Jenny Veillard,
Nneka Nzekwu,
Okema Torey,
Omehvy George,
Prince Adeparusi,
Rebecca Agyeiwaa Annoh,
Regina Nkechi Emmanuel,
Rose Freeman,
Salamat Yusifu,
Scholastica Tandongfor,
Soeurette Colin,
Sofia Lamarre,
Sonia Jones,
Stella Agyenim Boateng,
Sunday Odeh,
Theodora Alexander,
Veronique Lahens,
and
Betty A. Rosa
In Her Capacity As Commissioner Of The New York State Education Department,
David Hamilton
In His Official Capacity As The Assistant Commissioner For Professional Licensing And Practice For The Nys Dept. Of Education Office Of Professions,
New York State Education Department,
New York State Office Of The Professions,
Sarah Benson
In Her Official Capacity As Deputy Commissioner Of The Nys Dept. Of Education And As The Official Heading The Office Of The Professions,
for Special Proceedings - CPLR Article 78
in the District Court of Albany County.
Preview
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/21/2024
July 10, 2023
VIA EMAIL: OPDPLS@nysed.gov and
USPS
David Hamilton, LMSW
Assistant Commissioner, OP
State Education Department
DPLS Director’s Office
89 Washington Avenue
Albany, New York 12234-1000
RE: Karen Saulong
RN License No. 764612
Dear Mr. Hamilton:
On behalf of Karen Saulong, RN/BSN, we write continuance of cooperation with your office and
your inquiry about our client’s education and qualifications. Nurse Saulong has been licensed as
an RN in New York State since February 22, 2019. Enclosed herewith is a jump drive with
materials we have gathered to demonstrate Nurse Saulong’s qualifications and competence. Also
enclosed is an index of those materials, to help with your review, attached as Exhibit A.
Our prior correspondence
As a reminder, we sent you correspondence on February 14, 2023, advising that this office had
been retained by several nurses who received correspondence from you regarding the nursing
schools they attended in Florida and demanding that they surrender their licenses. On February
15, 2023, we sent you a letter specific to Karen Saulong, which letter is attached as Exhibit B. We
have written you several subsequent letters as additional nurses retained us after receiving similar
correspondence from you. We have received no response to any of our letters, even though each
of them indicates an intention to cooperate and requests a conference to discuss a reasonable
resolution of these matters.
EXHIBIT K - Saulong, K 7.10.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/21/2024
No grounds for summary suspension
As briefly described in our prior letter, there are no grounds for a summary suspension of Nurse
Saulong’s license. This nurse poses no threat to the public health imperatively requiring
emergency action. (See Commissioner’s Reg. 17.9). She neither committed nor knowingly
participated in any fraud. As described more fully below and in the enclosed materials, Nurse
Saulong did attend and complete her nursing education at Palm Beach School of Nursing. Some
of Nurse Saulong’s education, including her clinical training, was completed at Helene Fuld
College of Nursing. Palm Beach School of Nursing accepted transfer credit for her training at
Helene Fuld College of Nursing, and she then attended further classroom instruction at Palm Beach
School of Nursing. Nurse Saulong then passed the NCLEX. The fact that a nursing school
attended by this nurse may have also sold or given out fraudulent degrees to other students does
not render this nurse a threat to the public health. We believe your office is aware of this fact,
since nearly six months have passed since your initial letter to Nurse Saulong and no direct action
has been taken, nor has any proceeding been commenced against her license.
No misconduct or other grounds for discipline
Nurse Saulong is entitled to retain her RN license. She obtained this license in full compliance
with applicable law. She completed the educational requirement for licensure in accordance with
Commissioner’s Reg. 52.12(a)(2) by completing a program in nursing approved by the licensing
authority of Florida for practice as a Registered Professional Nurse. She was authorized to sit for
the NCLEX and passed the exam. These were the legal requirements for obtaining her RN license.
Absent any fraud on her part, and there was none, there is no basis to take her license from her.
The fact that this regulation has since been amended to create a specific carve out for Palm Beach
School of Nursing as well as a few other schools does not have a retroactive effect on Nurse
Saulong’s credentials, which met the requirements applicable at the time.
Nurse Saulong has clearly and obviously committed no fraud. The degree she obtained from Palm
Beach School of Nursing (hereinafter “PBSON”) was not purchased; it was earned. Prior to
attending PBSON, she completed a practical nursing program at Lincoln Technical Institute,
passed her NCLEX-PN, and received her NY LPN license on May 6, 2011. Documents related to
her LPN license are included as Exhibit A in the materials contained on the jump drive provided
with this letter. She had earned college credit at Union County College and Excelsior College.
Furthermore, she completed 70.50 credit hours in an A.A.S. in Nursing program at Helene Fuld
College of Nursing. (Exhibit B)
As part of her application process to PBSON, Nurse Saulong submitted her transcripts from Helene
Fuld College of Nursing, the completed PN program and other prior college credits. She attended
classes, all of which were in person at the PBSON satellite campus located in Brooklyn, New
York. Her RN education included examinations and other written assessments. She retained some
of her course presentation materials, which are included at Exhibit C on the jump drive submitted
with this letter.
EXHIBIT K - Saulong, K 7.10.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/21/2024
Nurse Saulong completed approximately 720 clinical hours while in the A.A.S. Nursing program
at Helene Fuld College of Nursing, before transferring to PBSON to complete her eduction.
Given these facts, it cannot reasonably be suggested that Nurse Saulong participated in any fraud
or made any material misrepresentations on her license application materials.
Nurse Saulong’s competence as an RN is well established
In addition to the education discussed above, Nurse Saulong earned her Bachelor of Science in
Nursing from Chamberlain University in 2019. She was required to complete a professional
capstone and practicum course. (Exhibit F)
Prior to earning her RN, for several years Nurse Saulong worked as an LPN providing direct
patient care at Axion Agency (2011) and Brooklyn Veterans Hospital (2011 – 2020). Her job
duties included triage, vaccine and medication administration, pre-visit calls, phlebotomy, ekg,
blood pressure and glucometer teachings, as well as other clinical duties.
Since earning her RN, Nurse Saulong has worked as an RN with Golden Gate Rehabilitation and
Health Center and Brooklyn Veterans Hospital where she provides direct patient care. Her duties
include working with physicians, LPNs and patients at the Primary Care Clinic/Geriatric specialty.
She collaborates with social work, psychology, psychiatry, pharmacy, and neuropsychology. She
triages patients per their visits, takes vital signs, and satisfies other identified reminders by
screening patients, assessing them if in need of services at homes such as Home Health Aids or
medical equipment. She assesses patients through questions related to mental well being, social
support, and physical capacity. If collaboration with other teamlets is needed, Nurse Saulong
reaches out directly to the other teamlets or speaks with the attending physician depending on the
need. In clinic, Nurse Saulong takes vital signs, and administers vaccines and medications. She
regularly educations patients on: blood pressure measurement, insulin administration, finger stick
blood testing, fall prevention, ER admission prevention, and other health subject.
Nurse Saulong makes pre-visit and post-visit calls to patient to maximize the benefit of each visit
and to follow up on the patient’s condition, assist with obtaining follow up appointments with
providers, and to prevent re-admission. She assesses walk-in patients with various issues ranging
from medication refills to acute medical needs. Nurse Saulong collaborates with providers
depending on patient needs whether to contact pharmacy, send the patients to the ER, or other
appropriate medical departments. She performs minor wound dressing changes, answers patient
calls and addresses their various needs.
Nurse Saulong covers the urgent care center as well, where she assist providers with various patient
needs including oral or injectable medication administration, patient education, wound care, and
phlebotomy. Nurse Saulong collaborates with the Emergency Department and the pharmacy
depending on patient needs.
During the height of COVID in 2020 Nurse Saulong was deployed to the med-surg unit for 4-5
months where she took care of COVID patients. In the med-surg unit she collaborated with other
nurses (nurse to patient ratio 1:4-6), physicians and the pharmacy to provide care for patients.
EXHIBIT K - Saulong, K 7.10.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/21/2024
She administered medications including oral, injections, topical, IV. Currently, she also
performs phlebotomies, workswith aids to provide patient care, feeds, and helps patients get in
touch with families via iPad.
Nurse Saulong has earned recognition for her outstanding work as an RN from the Department of
Veterans Affairs. In keeping with the long-standing military tradition of showing appreciation for
outstanding job performance by coining, Nurse Saulong has twice been the recipient of
commander’s coins. She also received an individual cash award. (Exhibit H)
Conclusion
For the reasons stated above, and based on the evidence enclosed, it is clear Nurse Saulong lawfully
obtained her nursing license and has gone on to advance her training and to provide professional
nursing services. It is equally clear that Nurse Saulong is an asset to the public health of New York
State, and especially to our military veterans. We respectfully submit that it would be consistent
with the Department’s mandate to protect, rather than destroy, this nurse’s ability to practice.
We are willing, even eager, to discuss a way to resolve this issue and address the Department’s
concerns regarding Nurse Saulong’s education and training. Please call or email me anytime to
have that discussion.
Very truly yours,
ADDELMAN CROSS & BALDWIN, PC
Jesse B. Baldwin
JBB/ba
EXHIBIT K - Saulong, K 7.10.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/21/2024
INDEX OF SUPPORTING DOCUMENTATION
ON BEHALF OF
KAREN SAULONG, RN
School Attended: Palm Beach School of Nursing
Dates of Attendance: 8/8/2016 – 4/27/2018
A. Licensed Practical Nurse
1. License Number 305712
2. Registration Certificate, valid through 7/31/2025
3. Lincoln Technical Institute transcript
a. Practical Nursing, Graduation Date 3/10/2011
B. Previous Education
1. Helene Fuld College of Nursing
a. Transcript – completed 70.50 credit hours
b. Course Descriptions
2. Union County College
a. Transcript
3. Excelsior College
a. Transcript
C. Palm Beach School of Nursing, Associates of Science of Nursing
1. Documents specific to Karen Saulong
a. Official Transcript, dates attended: 8/8/2016 – 4/27/2018
b. Receipt
2. General Admission and Orientation Documents
a. Brochure – Nursing Associate of Science
b. Entrance Packet
c. Nursing – Associate of Science Course Description
d. Entrance Exam Subjects
e. Admissions profile form
f. Welcome letter describing SHOMA – popular custom rooming arrangement
g. DocuNow drug testing
3. General Documents
a. Promotional Flyer for Palm Beach School of Nursing - “Open Enrollment! No
Waiting Lists!”
EXHIBIT K - Saulong, K 7.10.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/21/2024
b. “NY Board of Nursing – Things you need”
4. Course Materials
a. Course Syllabuses
i. HSC 104, Pathophysiology
ii. Nur 100, LPN to RN Transition
iii. Nur 101, Introduction to Health Care
iv. Nur 101, Fundamentals of Nursing
v. Nur 103, Pharmacology
vi. Nur 104, Critical Thinking and the Nursing Process
vii. Nur 201, Adult Nursing I
viii. Nur 203, Psychiatric and Mental Health Nursing
ix. Nur 205, Maternal Child Nursing
x. Nur 207, Pediatric Nursing
xi. Nur 301, Adult Nursing II
xii. Nur 402, Professional Nursing Leadership
xiii. Internet Resources to Improve Learning, Reading, Studying & Test
Taking
b. Select Course Chapters
i. Wolters Kluwer, Chapter 22 – Nurse Leader, Manager & Care
Coordinator
ii. Wolters Kluwer, Chapter 23 - Asepsis and Infection Control
iii. Wolters Kluwer, Chapter 26 – Safety, Security, and Emergency
Preparedness
iv. Wolters Kluwer, Chapter 31, Skin Integrity and Wound Care
v. Mosby, Chapter 23 – Postpartum Complications
vi. Mosby, Chapter 24 – Physiologic Adaptations of the Newborn
c. Exams / Homework
i. Critical Thinking, Homework 1, due 8/3/17
ii. Pharmacology Exam, 10/3/2017
d. Psychiatry – Pharmacology – Psychiatric condition preferred drugs
e. Class Schedule & Roster – February 2017 – December 2017
f. 2017 Holiday Schedule
g. Exit Exam – HESI Account
D. NCLEX documents
1. Authorization to Test, test validity 16 October 2018 – 14 January 2019
E. NYS Registered Professional Nurse
1. License Number 764612, issued 2/22/2019
2. Registration Certificate, valid through 7/31/2024
EXHIBIT K - Saulong, K 7.10.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/21/2024
F. Post RN License Education
1. Certificates of CE courses completed through the VA
a. Physical Assessment Refresher for Nurses, 6.5 hours, completed 5/19/2021
b. Diabetes Management, 6.5 hours, Completed 12/16/2021
c. Clinical Nursing Update, 1 hour, Completed 08/18/2021
d. Diabetes Management, 6.5 hours, Completed 06/16/2022
2. Chamberlin University, Bachelor of Science in Nursing, Completed October 26, 2019
a. Transcript
b. Degree
c. Grades and evidence of Capstone Project
G. Recognition received for work as a Registered Nurse
1. Awards from employer, Department of Veteran Affairs
a. Individual Cash Award
b. “Coin” Awards
EXHIBIT K - Saulong, K 7.10.2023 Baldwin - NYSED with index
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/21/2024
From: Jesse Baldwin
To: OPDPLS
Cc: Beth Atwood
Subject: Karen Saulong, RN License No. 764612
Date: Monday, July 10, 2023 2:38:23 PM
Attachments: Saulong__Karen_-_Submission_letter_NY_OP.docx
INDEX_OF_SUPPORTING_DOCUMENTATION_-_Saulong__Karen.docx
image001.png
Dear Mr. Hamilton:
In furtherance of this licensee’s cooperation with the Office of the Professions, attached please find
a letter submission on behalf of Karen Saulong, RN, as well as an index of the voluminous supporting
documentation. The documents referred to in the index are included in a jump drive that is being
mailed to you with a paper copy of the letter and index. I look forward to speaking with you
regarding Nurse Saulong. Thank you for you kind attention.
Jesse B. Baldwin | Partner
Addelman Cross & Baldwin, PC
5680 Main Street | Buffalo, New York 14221
716-868-5099 | jbaldwin@acbfirm.com | www.acbfirm.com
Statement of Confidentiality: This electronic message may contain privileged or confidential information.
If you are not the intended recipient of this e-mail, please delete it from your system and advise the sender.
EXHIBIT K - Saulong, K 7.10.2023 Baldwin - NYSED with index
Preview
FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/21/2024 July 10, 2023 VIA EMAIL: OPDPLS@nysed.gov and USPS David Hamilton, LMSW Assistant Commissioner, OP State Education Department DPLS Director’s Office 89 Washington Avenue Albany, New York 12234-1000 RE: Karen Saulong RN License No. 764612 Dear Mr. Hamilton: On behalf of Karen Saulong, RN/BSN, we write continuance of cooperation with your office and your inquiry about our client’s education and qualifications. Nurse Saulong has been licensed as an RN in New York State since February 22, 2019. Enclosed herewith is a jump drive with materials we have gathered to demonstrate Nurse Saulong’s qualifications and competence. Also enclosed is an index of those materials, to help with your review, attached as Exhibit A. Our prior correspondence As a reminder, we sent you correspondence on February 14, 2023, advising that this office had been retained by several nurses who received correspondence from you regarding the nursing schools they attended in Florida and demanding that they surrender their licenses. On February 15, 2023, we sent you a letter specific to Karen Saulong, which letter is attached as Exhibit B. We have written you several subsequent letters as additional nurses retained us after receiving similar correspondence from you. We have received no response to any of our letters, even though each of them indicates an intention to cooperate and requests a conference to discuss a reasonable resolution of these matters. EXHIBIT K - Saulong, K 7.10.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/21/2024 No grounds for summary suspension As briefly described in our prior letter, there are no grounds for a summary suspension of Nurse Saulong’s license. This nurse poses no threat to the public health imperatively requiring emergency action. (See Commissioner’s Reg. 17.9). She neither committed nor knowingly participated in any fraud. As described more fully below and in the enclosed materials, Nurse Saulong did attend and complete her nursing education at Palm Beach School of Nursing. Some of Nurse Saulong’s education, including her clinical training, was completed at Helene Fuld College of Nursing. Palm Beach School of Nursing accepted transfer credit for her training at Helene Fuld College of Nursing, and she then attended further classroom instruction at Palm Beach School of Nursing. Nurse Saulong then passed the NCLEX. The fact that a nursing school attended by this nurse may have also sold or given out fraudulent degrees to other students does not render this nurse a threat to the public health. We believe your office is aware of this fact, since nearly six months have passed since your initial letter to Nurse Saulong and no direct action has been taken, nor has any proceeding been commenced against her license. No misconduct or other grounds for discipline Nurse Saulong is entitled to retain her RN license. She obtained this license in full compliance with applicable law. She completed the educational requirement for licensure in accordance with Commissioner’s Reg. 52.12(a)(2) by completing a program in nursing approved by the licensing authority of Florida for practice as a Registered Professional Nurse. She was authorized to sit for the NCLEX and passed the exam. These were the legal requirements for obtaining her RN license. Absent any fraud on her part, and there was none, there is no basis to take her license from her. The fact that this regulation has since been amended to create a specific carve out for Palm Beach School of Nursing as well as a few other schools does not have a retroactive effect on Nurse Saulong’s credentials, which met the requirements applicable at the time. Nurse Saulong has clearly and obviously committed no fraud. The degree she obtained from Palm Beach School of Nursing (hereinafter “PBSON”) was not purchased; it was earned. Prior to attending PBSON, she completed a practical nursing program at Lincoln Technical Institute, passed her NCLEX-PN, and received her NY LPN license on May 6, 2011. Documents related to her LPN license are included as Exhibit A in the materials contained on the jump drive provided with this letter. She had earned college credit at Union County College and Excelsior College. Furthermore, she completed 70.50 credit hours in an A.A.S. in Nursing program at Helene Fuld College of Nursing. (Exhibit B) As part of her application process to PBSON, Nurse Saulong submitted her transcripts from Helene Fuld College of Nursing, the completed PN program and other prior college credits. She attended classes, all of which were in person at the PBSON satellite campus located in Brooklyn, New York. Her RN education included examinations and other written assessments. She retained some of her course presentation materials, which are included at Exhibit C on the jump drive submitted with this letter. EXHIBIT K - Saulong, K 7.10.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/21/2024 Nurse Saulong completed approximately 720 clinical hours while in the A.A.S. Nursing program at Helene Fuld College of Nursing, before transferring to PBSON to complete her eduction. Given these facts, it cannot reasonably be suggested that Nurse Saulong participated in any fraud or made any material misrepresentations on her license application materials. Nurse Saulong’s competence as an RN is well established In addition to the education discussed above, Nurse Saulong earned her Bachelor of Science in Nursing from Chamberlain University in 2019. She was required to complete a professional capstone and practicum course. (Exhibit F) Prior to earning her RN, for several years Nurse Saulong worked as an LPN providing direct patient care at Axion Agency (2011) and Brooklyn Veterans Hospital (2011 – 2020). Her job duties included triage, vaccine and medication administration, pre-visit calls, phlebotomy, ekg, blood pressure and glucometer teachings, as well as other clinical duties. Since earning her RN, Nurse Saulong has worked as an RN with Golden Gate Rehabilitation and Health Center and Brooklyn Veterans Hospital where she provides direct patient care. Her duties include working with physicians, LPNs and patients at the Primary Care Clinic/Geriatric specialty. She collaborates with social work, psychology, psychiatry, pharmacy, and neuropsychology. She triages patients per their visits, takes vital signs, and satisfies other identified reminders by screening patients, assessing them if in need of services at homes such as Home Health Aids or medical equipment. She assesses patients through questions related to mental well being, social support, and physical capacity. If collaboration with other teamlets is needed, Nurse Saulong reaches out directly to the other teamlets or speaks with the attending physician depending on the need. In clinic, Nurse Saulong takes vital signs, and administers vaccines and medications. She regularly educations patients on: blood pressure measurement, insulin administration, finger stick blood testing, fall prevention, ER admission prevention, and other health subject. Nurse Saulong makes pre-visit and post-visit calls to patient to maximize the benefit of each visit and to follow up on the patient’s condition, assist with obtaining follow up appointments with providers, and to prevent re-admission. She assesses walk-in patients with various issues ranging from medication refills to acute medical needs. Nurse Saulong collaborates with providers depending on patient needs whether to contact pharmacy, send the patients to the ER, or other appropriate medical departments. She performs minor wound dressing changes, answers patient calls and addresses their various needs. Nurse Saulong covers the urgent care center as well, where she assist providers with various patient needs including oral or injectable medication administration, patient education, wound care, and phlebotomy. Nurse Saulong collaborates with the Emergency Department and the pharmacy depending on patient needs. During the height of COVID in 2020 Nurse Saulong was deployed to the med-surg unit for 4-5 months where she took care of COVID patients. In the med-surg unit she collaborated with other nurses (nurse to patient ratio 1:4-6), physicians and the pharmacy to provide care for patients. EXHIBIT K - Saulong, K 7.10.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/21/2024 She administered medications including oral, injections, topical, IV. Currently, she also performs phlebotomies, workswith aids to provide patient care, feeds, and helps patients get in touch with families via iPad. Nurse Saulong has earned recognition for her outstanding work as an RN from the Department of Veterans Affairs. In keeping with the long-standing military tradition of showing appreciation for outstanding job performance by coining, Nurse Saulong has twice been the recipient of commander’s coins. She also received an individual cash award. (Exhibit H) Conclusion For the reasons stated above, and based on the evidence enclosed, it is clear Nurse Saulong lawfully obtained her nursing license and has gone on to advance her training and to provide professional nursing services. It is equally clear that Nurse Saulong is an asset to the public health of New York State, and especially to our military veterans. We respectfully submit that it would be consistent with the Department’s mandate to protect, rather than destroy, this nurse’s ability to practice. We are willing, even eager, to discuss a way to resolve this issue and address the Department’s concerns regarding Nurse Saulong’s education and training. Please call or email me anytime to have that discussion. Very truly yours, ADDELMAN CROSS & BALDWIN, PC Jesse B. Baldwin JBB/ba EXHIBIT K - Saulong, K 7.10.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/21/2024 INDEX OF SUPPORTING DOCUMENTATION ON BEHALF OF KAREN SAULONG, RN School Attended: Palm Beach School of Nursing Dates of Attendance: 8/8/2016 – 4/27/2018 A. Licensed Practical Nurse 1. License Number 305712 2. Registration Certificate, valid through 7/31/2025 3. Lincoln Technical Institute transcript a. Practical Nursing, Graduation Date 3/10/2011 B. Previous Education 1. Helene Fuld College of Nursing a. Transcript – completed 70.50 credit hours b. Course Descriptions 2. Union County College a. Transcript 3. Excelsior College a. Transcript C. Palm Beach School of Nursing, Associates of Science of Nursing 1. Documents specific to Karen Saulong a. Official Transcript, dates attended: 8/8/2016 – 4/27/2018 b. Receipt 2. General Admission and Orientation Documents a. Brochure – Nursing Associate of Science b. Entrance Packet c. Nursing – Associate of Science Course Description d. Entrance Exam Subjects e. Admissions profile form f. Welcome letter describing SHOMA – popular custom rooming arrangement g. DocuNow drug testing 3. General Documents a. Promotional Flyer for Palm Beach School of Nursing - “Open Enrollment! No Waiting Lists!” EXHIBIT K - Saulong, K 7.10.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/21/2024 b. “NY Board of Nursing – Things you need” 4. Course Materials a. Course Syllabuses i. HSC 104, Pathophysiology ii. Nur 100, LPN to RN Transition iii. Nur 101, Introduction to Health Care iv. Nur 101, Fundamentals of Nursing v. Nur 103, Pharmacology vi. Nur 104, Critical Thinking and the Nursing Process vii. Nur 201, Adult Nursing I viii. Nur 203, Psychiatric and Mental Health Nursing ix. Nur 205, Maternal Child Nursing x. Nur 207, Pediatric Nursing xi. Nur 301, Adult Nursing II xii. Nur 402, Professional Nursing Leadership xiii. Internet Resources to Improve Learning, Reading, Studying & Test Taking b. Select Course Chapters i. Wolters Kluwer, Chapter 22 – Nurse Leader, Manager & Care Coordinator ii. Wolters Kluwer, Chapter 23 - Asepsis and Infection Control iii. Wolters Kluwer, Chapter 26 – Safety, Security, and Emergency Preparedness iv. Wolters Kluwer, Chapter 31, Skin Integrity and Wound Care v. Mosby, Chapter 23 – Postpartum Complications vi. Mosby, Chapter 24 – Physiologic Adaptations of the Newborn c. Exams / Homework i. Critical Thinking, Homework 1, due 8/3/17 ii. Pharmacology Exam, 10/3/2017 d. Psychiatry – Pharmacology – Psychiatric condition preferred drugs e. Class Schedule & Roster – February 2017 – December 2017 f. 2017 Holiday Schedule g. Exit Exam – HESI Account D. NCLEX documents 1. Authorization to Test, test validity 16 October 2018 – 14 January 2019 E. NYS Registered Professional Nurse 1. License Number 764612, issued 2/22/2019 2. Registration Certificate, valid through 7/31/2024 EXHIBIT K - Saulong, K 7.10.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/21/2024 F. Post RN License Education 1. Certificates of CE courses completed through the VA a. Physical Assessment Refresher for Nurses, 6.5 hours, completed 5/19/2021 b. Diabetes Management, 6.5 hours, Completed 12/16/2021 c. Clinical Nursing Update, 1 hour, Completed 08/18/2021 d. Diabetes Management, 6.5 hours, Completed 06/16/2022 2. Chamberlin University, Bachelor of Science in Nursing, Completed October 26, 2019 a. Transcript b. Degree c. Grades and evidence of Capstone Project G. Recognition received for work as a Registered Nurse 1. Awards from employer, Department of Veteran Affairs a. Individual Cash Award b. “Coin” Awards EXHIBIT K - Saulong, K 7.10.2023 Baldwin - NYSED with index FILED: ALBANY COUNTY CLERK 02/21/2024 11:40 AM INDEX NO. 901869-24 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 02/21/2024 From: Jesse Baldwin To: OPDPLS Cc: Beth Atwood Subject: Karen Saulong, RN License No. 764612 Date: Monday, July 10, 2023 2:38:23 PM Attachments: Saulong__Karen_-_Submission_letter_NY_OP.docx INDEX_OF_SUPPORTING_DOCUMENTATION_-_Saulong__Karen.docx image001.png Dear Mr. Hamilton: In furtherance of this licensee’s cooperation with the Office of the Professions, attached please find a letter submission on behalf of Karen Saulong, RN, as well as an index of the voluminous supporting documentation. The documents referred to in the index are included in a jump drive that is being mailed to you with a paper copy of the letter and index. I look forward to speaking with you regarding Nurse Saulong. Thank you for you kind attention. Jesse B. Baldwin | Partner Addelman Cross & Baldwin, PC 5680 Main Street | Buffalo, New York 14221 716-868-5099 | jbaldwin@acbfirm.com | www.acbfirm.com Statement of Confidentiality: This electronic message may contain privileged or confidential information. If you are not the intended recipient of this e-mail, please delete it from your system and advise the sender. EXHIBIT K - Saulong, K 7.10.2023 Baldwin - NYSED with index