Dear Members of the Board, 

The Home Care & Hospice Alliance of Maine appreciates the opportunity to provide feedback on the proposed rule regarding the delegation of nursing activities and tasks to Unlicensed Assistive Personnel (UAP) by Registered Professional Nurses (RNs). 

We are strongly supportive of this proposed rule. Allowing RNs the option to delegate appropriate tasks to UAPs is a critical step toward strengthening Maine’s care delivery system, particularly in the home care and hospice settings, where workforce challenges and rising patient needs continue to intensify. 

Importantly, this rule does not mandate delegation. Rather, it provides RNs with a flexible, clinically sound tool they may use at their discretion. Delegation remains firmly grounded in the nurse’s professional judgment. The RN retains full authority to determine whether a task is appropriate to delegate, to oversee the delegated activity, and to modify or revoke that delegation at any time based on the patient’s condition, the competence of the UAP, or other relevant factors. 

By creating this option, not an obligation, the rule empowers nurses to practice at the top of their license. This supports more efficient care delivery, improves patient access, and helps ensure that nurses can focus their expertise where it is most needed. 

For home care in particular, the ability to safely delegate tasks to trained UAPs is essential. Maine continues to face a significant nursing shortage, especially in rural and underserved areas. Many patients who wish to remain at home struggle to receive timely services simply because a registered nurse is not available to complete every task personally. Delegation, when appropriate, can expand capacity, support continuity of care, and allow more Mainers to receive high-quality services in the setting they prefer, their home. 

The Alliance strongly supports moving forward with this rule as written. It offers an evidence-based, patient-centered approach that maintains safety, preserves RN oversight, and addresses real workforce pressures in our state’s home health and hospice communities. 

Thank you for your consideration and for your ongoing commitment to advancing safe, high-quality nursing care in Maine. We appreciate the opportunity to comment and stand ready to support the successful implementation of this important rule. 

Sincerely, 

Sara Ratcliffe 

Executive Director 
Home Care & Hospice Alliance of Maine (now Maine Alliance for Care at Home)