i facilitating the transition into nursing...

J O U R N A L F O R N U R S E S I N S T A F F D E V E L O P M E N T � Volume 20, Number 6, 274–284� A 2004 � Lippincott Williams & Wilkins, Inc.

Because of nursing shortages, hospitals have in-creased their hiring of new graduate nurses. The

transition from school into practice poses uniqueissues and challenges for the staff, the new graduate,and the staff development department. Orientationprograms need to be tailored to inexperienced nursesto foster safe, competent practice yet remain cost-effective for the organization.

New nursing graduates are expected to translateknowledge, principles, and theories learned in schoolinto their practice in a particular setting with spe-cific patient populations. This application to practicenot only encompasses new clinical skills and tech-niques but also includes coping with issues of rela-tionships with patients and families, organizationalstructure, and group work that may be new to them.

CURRENT TRENDS

The current shortage of registered nurses in the UnitedStates appears to be different and more complex thanthe shortages in the past. Supply and demand issues,increasing opportunities in other careers, limitedwages, the nursing workforce, and work environment

are contributing factors. Factors affecting the supply ofnurses include the fluctuating enrollments in nursingschools and an increased variety of career options thatare less physically demanding with better wages(Minnick, 2000). The age of the nursing workforcehas increased during the past 25 years, and feweryoung persons are entering the nursing profession.People born between 1947 and 1962, known as babyboomers, make up the largest group of U.S. registerednurses based on the data of the National SampleSurvey of Registered Nurses (Division of Nursing, U.S.Bureau of Health Professions, 1997). As these babyboomers reach retirement age, the issue that only 9%of registered nurses are younger than 30 yearsbecomes a major concern. The demand for nursesvaries according to different reports, but the agingof society and the subsequent healthcare demandsindicate that the need for nurses will increase by asmuch as 22% between 1998 and 2008.

Among the approximately 2 million registerednurses in the United States, 83% are working as nurses,indicating a high labor percentage that leaves littleroom for expanded participation (U.S. Departmentof Labor, 2000). Hospitals employ about 60% of allnurses, and nurses are more likely to work in hospitalswhen they are younger (Minnick, 2000). The strainof physically demanding work, along with working

Facilitating the Transition

Into Nursing Practice

Concepts and Strategies for MentoringNew Graduates

Joan Santucci, MN, RN, ONC

K E Y WORDS � ORIENTATION � TRANSITION � MENTORING................................................

In today’s healthcare market, current trends

in the nursing population are posing

problems in the workforce. With the present

nursing shortage, hospitals are competing

for the hiring of new graduate nurses. To

recruit, retain, and foster personal and

professional growth, employers must be

aware of the gaps between skills and

knowledge acquired in school and those

gained through experience. Employer

expectations of new graduate nurses and

concepts to support new graduate nurses are

explored. From these concepts, components

of a specialty orientation program are

described to assist the transition from student

to nurse.

..............................................

..........................................Joan Santucci, MN, RN, ONC, is Clinical Nurse Specialist at HarborviewMedical Center, Seattle, Washington.

274 November/December 2004

Copyr ight © Lippincott Williams & Wilkins. Unauthorized reproduction of this article is prohibited.

evening and night shifts, most likely contributes to thedesire for older nurses to seek employment outsidethe hospital setting. These issues pose challenges forrecruitment and retention strategies, as well as pro-viding work environments that promote relationsbetween generational nurses (Santos, 2002). Workplaceenvironment is often cited as the cause of job turnoverbecause of difficult patient caseloads, scheduling, andpatient safety issues (Santos, 2002). It is clear thathospitals must provide environments that foster inte-gration into the system and are conducive to recruitingand retaining new graduates, yet they must remaincost-effective in providing orientation programs.

EFFECTS OF INCREASED HIRING OFNEW GRADUATE NURSES

The nursing shortage affects hospitals in terms ofoperational issues, vacancy rates for registered nurses,and perceived quality of patient care. In response,hospitals have increased the number of new graduatenurses into the hiring pool (American Organization ofNurse Executives’ Institute for Patient Care Researchand Education, 2002). However, there is a scarcityof literature discussing the effects of this increasednumber of new graduates practicing in hospitals. Theseeffects were reviewed in a teaching hospital in thePacific Northwest, which mirrored the national in-crease in nurse graduate hires. This hospital estab-lished a residency program for graduate nurses withthe goal of recruiting and retaining nurses in what wasperceived by many students as a fast-paced, high-acuitywork setting. Over the years, the number of residencyprograms and participants increased substantially inthis hospital. This influx of new graduates led to ahigher ratio of inexperienced nurses in direct patientcare, especially on the night shift where typically fewerresources are available. The residency program wasinitially intended for the medical–surgical acute careunits but was expanded into critical care, psychiatry,and the perioperative areas to improve staffing. Thecritical care units, which were accustomed to experi-enced nurses, specifically felt the impact.

With the large influx of new graduates, preceptorissues surfaced. The limited availability of preceptorsled to inconsistent assignments with multiple precep-tors, presenting problems with communication, followthrough, and evaluation of goals and progress. Theoveruse of individuals as preceptors presents thepotential for burnout.

From the organizational perspective, other prob-lems surfaced. The cost of orientation programs canbe significant. Staffing issues, scheduling, varying unitexpectations, and program coordination contributedto these challenges and changes.

WHAT WE EXPECT GRADUATES TOLEARN FROM PRACTICE

To develop a specialty orientation program for grad-uates, awareness of skills and growth, which are gainedfrom experience as well as from challenges facedby the transition from student to nurse, are valuablefor enhancing the methods and programs that assistentry into practice. These factors, once identified, canform the framework for the development of a specialtyorientation program.

Benner’s (1984) model of the developmental stagesof proficiency in skill acquisition is a commonframework that exemplifies graduates as advancedbeginners. The clinical world of advanced beginnersis characterized by their focus on competing tasks,difficulty managing competing demands, and theinability to adequately prioritize clinical situations andinterventions. Advanced beginners tend to delegate tomore experienced clinicians when faced with difficultsituations, trusting that more experienced clinicians orthose at a perceived higher level of authority automat-ically know how to problem-solve and will take overfor them (Benner, Tanner, & Chesla, 1996). Advancedbeginners’ lack of experience results in limitations inperceptions of the clinical situation and limited self-confidence to problem-solve, which subsequently limittheir clinical interventions.

The transition from student to nurse offers learningexperiences beyond those acquired in school. Many ofthe concepts learned can only be internalized throughpersonal experience. It is as if school prepares studentswith the tools to think and intervene as a nurse, whilework experience enhances their ability to apply anduse those tools. In the workplace, the realities of pa-tient care give nurses the chance to apply the theorieslearned and to identify situations that are or are notsupported by those theories.

From a review of the literature on transition topractice, in addition to personal experience workingwith this population, three concepts emerge thatdescribe the areas of growth gained from experience:role integration, clinical and interpersonal skills, andreshaping of values.

Role Integration

Role integration describes the discovery and sense of selfas a nurse. Encountering new situations and discoveringnew ways of seeing and responding are powerful forcesthat shape nurses’ personal identity. Personal standardsof practice become developed and more evident withexperience. Nurses begin to develop self-confidenceand their own ‘‘voices’’ as nurses. These new-livedexperiences provide nurses with ways of making

JOURNAL FOR NURSES IN STAFF DEVELOPMENT 275


meaning of their work and provide avenues for contin-ued personal growth and professional development.

Clinical and Interpersonal Skills

Relationships with others on the healthcare teamaffect the feeling of belonging in the nursing profes-sion and in the workplace. With the transition fromnewcomer to insider comes the pressure to fit into theculture of the workplace. Dealing with resistant staff,feeling uncomfortable with posing new ideas orquestioning accepted practice, and negotiating withphysicians are skills that are expected to be encoun-tered and learned from practice. Learning to workas a member of the team involves establishing rela-tionships, exploring organizational expectations, andassimilating professional socialization. The tendencyto rely emotionally and clinically on experienced staffis expected to shift to taking more responsibilityfor clinical judgments and for voicing disagreementswith physicians and experienced nurses (Benneret al., 1996).

Certain organizational skills are expected to beacquired in practice. New hires are expected to graspknowledge and skills that are intangible, such asteamwork, system navigation, and the pace of theunit. New graduates are rarely prepared for the timemanagement skills that come with complex patientcare. Graduates are also expected to build clinical skillsin their specific practice area.

Reshaping of Values

Other powerful lessons learned in practice have to dowith reshaping ethics and values. New practitioners arefaced with situations that they cannot change or cure,such as the limitations of medical treatment, discharg-ing a patient from the hospital who is homeless, orpatients who refuse medical care. Nurses learn thelevel of involvement with patients and learn theboundaries of caring. Benner et al. (1996) stated thatby experience, nurses learn their authentic level ofinvolvement with patients, one that is balanced withtheir own feelings and lessons from going past thoseboundaries.

A central aspect of nursing is the concept of caring.Nurses experience not only different caring practicesbut also other phenomenon. The phenomenology ofknowing the patient (Tanner, Benner, Chesla, &Gordon, 1996), the ethic of care (Carse, 1996), andcompassion (Charon, 1996) are internal practices thatare learned through experience. Nurses often speakabout paradigm shifts and stories of patients who havehad a profound effect in shaping and refining theirinternal values.

EMPLOYER PERCEPTIONSAND EXPECTATIONS

As students make the transition to practice, theyencounter expectations as employees that may bedifferent from those expected of them as students.Most expectations are based in adult learning theoryand the shift to the learner as an active participant inthe learning process (Norton, 1998a). Consistent withthis paradigm, new graduates should be made awareof the inherent and often unspoken expectations ofemployers.

Upon employment, it is assumed that the graduatenurse is functioning at the advanced beginner level.In a study by Ramritu and Barnard (2001), new grad-uates described safe practice as working within theirlimits and accepting the fact that they have basic levelsof competence that require support and guidance.Bevis (1989) takes it a step farther and states thatsafety means more than performing technical taskscorrectly; it is also the ability to determine the heartof a problem and solve it creatively. In this sense,new graduates are assumed to have the skills to dothis at a basic level but would most likely need growthin this area.

Based on the understanding of this developmentallevel, new graduates are expected to know theirlimitations and to seek assistance as needed. As newmembers of the team, they are expected to participatein identifying their learning needs and to participate inplanning learning experiences and goals. This planningrequires collaboration with the preceptor, manager,and clinical educator to discuss progress and goalsetting.

New nurses are expected to be accountable for theirpractice and actions and to develop their own bestpractice. As students, they are often more knowledge-able about recent changes in standards than staffnurses in clinical settings. Employers expect them toraise questions about conflicting information andpractices. As newcomers, they have the advantage ofseeing things from new perspectives and can offerfresh ideas for positive change. Yet, expert staff nursesneed to remain aware of how difficult this is to do atthe advanced beginner level. Meeting these expec-tations and acknowledging these factors eventuallylead to integration with the team.

WHAT NEW GRADUATES SHOULDEXPECT FROM EMPLOYERS

The transition into the workplace can be stressfuland confusing. Clear communication of expectations,orientation, and performance can assist new graduatesin this transition. They deserve guidelines that enhance



their entry. The following guidelines can be viewed asa ‘‘bill of rights’’ for employment.

� Clearly stated expectations and criteria for com-petent performance are necessary. This includesproviding new staff with written performanceobjectives, criteria for competency, and the timeframes for accomplishing these objectives.

� Feedback about performance should be frequent,constructive, and provided verbally and in writing.

� Resources and support systems need to be availableand accessible to assist in learning.

� Consistent, qualified preceptors who are investedin the success of the new nurse are integral to asuccessful transition.

� A safe, trusting environment is necessary for col-laboration in the learning process and for individ-ual learning.

ORIENTATION PROGRAM COMPONENTS

Specialty orientation programs that support the transi-tion into practice should be based on the capacitiesof advanced beginners, expectations and guidelinesfrom the employer, and strategies for mentoring andenhancing transition. The essential components includea structured residency program, preceptor develop-ment, administrative support, tools for documentinglearning and performance, and innovative strategiesfor integrating theory and practice.

Residency Programs

The specialty orientation program for new graduates ata hospital in the Pacific Northwest has been in place for12 years and has undergone many changes in responseto changing trends in hiring and practice, cost-containment issues, and outcome monitoring. Cur-rently, it consists of a preceptored clinical experiencewith trained preceptors, classroom learning, andexpected time frames and criteria for completingorientation based on the area of practice. Although itis recognized that the length of time for orientationis individually based, guidelines were established forspecific clinical areas. The acute care graduates areexpected to require 8–12 weeks of orientation. Sincenurses new to critical care practice have additionalclasses during their orientation period, the length oforientation is extended to 20 weeks to ensure ade-quate clinical days with preceptors.

Administrative Support

Administrative support is essential to the success ofthe program. Participation and role clarification of all

people involved in the orientation process is crucial.The team typically involves the unit manager, clinicaleducator, preceptor(s), graduate nurse, staffing de-partment, unit staff, and administration. Throughcollaboration, guidelines were established on opera-tional issues, such as staffing, time frames to completeorientation, floating to different units, and shiftschedules.

Preceptor Development

The effectiveness of preceptor programs has beenwidely documented in the nursing literature andincludes the benefits of socialization, performance,professionalism, job satisfaction, retention, and costs(Olson et al., 2001). Preparation for staff in roledevelopment as a preceptor is essential. Preceptordevelopment programs described in the literatureincorporate components of characteristics and selec-tion of preceptors, role responsibilities, principles ofadult learning, communication skills, teaching tech-niques, and critical thinking concepts (Meng & Conti,1995). Ongoing support, education, and mentoring ofpreceptors are often provided by staff developmentspecialists (Schneller & Hoeppner, 1994), who fulfillthe roles of coach, facilitator, mentor, and consultant.These mentors assist the preceptors in assessingcompetency, giving feedback, identifying problemsand potential solutions, facilitating networking amongpreceptors, and revising the program. Meng and Conti(1995) pointed out that preceptors are often novicesthemselves in this role, and clinical nurse educatorsand staff development specialists become a ‘‘preceptorfor the preceptor.’’

Evaluation Tools

Tools for guiding and tracking learning and perfor-mance provide consistency among preceptors, docu-ment progress and goals, and can clarify learning needs.Some organizations have developed a learning pathwaythat delineates competencies and continued growth.These pathways provide an organized approach toessential components of orientation and are especiallyuseful when multiple preceptors are involved, ensuringconsistency in orientation content and skill acquisition(Evers, Odom, Latulip-Gardner, & Paul, 1994). Clinicaleducation staff at this hospital have developed compe-tency pathways for nurse orientation that are unitspecific, include general and specialty skill, and typesof patient diagnoses that are typical for each unit soall new hires will have gained experience in consis-tent clinical situations (Good & Schulman, 2000). Thecompetency pathways track learning for 3 yearsand are used in conjunction with annual performance



evaluations, informing staff that growth and learningcontinue after the initial orientation period.

It is recognized that nurses often have difficultygiving verbal and written feedback to orientees,especially if there are problems with performance orcommunication (Johantgen, 2001). Several differentmethods and instruments for evaluating clinical per-formance can be found in the literature (Gomez,Lobodzinski, & Hartwell, 1998). Clinical evaluationtools that measure the new graduates’ assimilation oflearning provide consistency in performance criteriaand ideally should be viewed as a review of skillsacquired and a learning plan to set goals and ob-jectives. The orientee is an integral part of this process.Both preceptor and orientee ideally formulate goalsand discuss performance assessment together. Theclinical evaluation tool at this hospital was developedwith preceptor involvement and, in the process,fostered teamwork, recognition, effectiveness, andideas for improvement. Categories for evaluation in-clude communication, critical thinking, integratingfeedback, and accountability (see Figure 1).

Integrating Theory and Practice

Learning experiences are optimized by inclusion ofmultiple strategies and techniques. In a review of theliterature on what nurses believed was important andhelpful, Meyer and Meyer (2000) found that thepractice of new clinical skills was identified as themost important factor in nursing orientation. In a studyof critical care orientees, Dunn and Fought (1994)found that observation of procedures, the practice ofnew skills away from the bedside, and case studyreviews were perceived as most useful.

Educators often use the cognitive, psychomotor,and affective domains as the framework for learning.Other principles include matching the desired out-come with the appropriate activity, considering theindividual learner, and sequencing learning fromsimple to complex (Norton, 1998a).

The cognitive domain refers to the knowledge,comprehension, application, analysis, and synthesis ofinformation (Norton, 1998b). This can be achieved byclassroom discussions specific to the patient popula-tion served. Nurses are required to make complexclinical decisions in daily practice, and much of theliterature emphasizes experience as a critical compo-nent in decision-making. Lacking this practical experi-ence, application to practice can be enhanced bydiscussion of case studies that involve clinical andintuitive judgment, critical thinking, negotiating withphysicians, and problem solving.

Benner (1984) pointed out that advanced begin-ners tend to focus on tasks. Psychomotor skills can be

practiced in a classroom or laboratory setting to de-crease the anxiety of fumbling with equipment at thebedside. Manipulation of hospital-specific equipmentand demonstration of technical skills with the pre-ceptor or clinical educator can ease this uncertainty.The classroom setting can also be used for new clinicalskills that may be specific for the patient populationserved.

The affective domain includes beliefs, values, andattitudes and is an important part of nursing educationin the clinical setting. Ethical challenges can surface fordiscussion in case study reviews. Eddy and Schermer(1999) described ‘‘shadowing’’ as a strategy where thelearner is paired with an expert, such as a clinical nursespecialist or nurse practitioner, to observe responsepatterns and behavior, which assists in learningnegotiating and in modeling professional nursing.Support group meetings have been incorporated intothe classroom agenda and are facilitated by clinicalnurse educators. These designated times allow fordiscussion of dilemmas, conflict resolution strategies,sharing and processing of experiences, and lead toreflective thought and integration. Discussions of themeaning of these new experiences helps nursesinterpret and understand behavior or care (Bevis,1989). On evaluation, the nurses overwhelminglyremark on the benefits of support group time inassisting them in their adjustment to practice.

PROGRAM EVALUATION

The evaluation of the program provides informationon effectiveness, efficiency, goals, and future trendsand needs. Several models for evaluation can be foundin the literature (Applegate, 1998). Meyer and Meyer(2000) describe a utilization-focused format to assesswhat aspects of an orientation program were effec-tive and what could be improved so nurses would feelcompetent in their role as hospital staff.

A summative evaluation that identifies the merit of aprogram and provides useful information on the extentto which a program is successful in meeting its goals isessentially a needs assessment. Using multiple datasources and combining qualitative and quantitativedata as methods of assessment is supported in theliterature (Witkin & Altschuld, 1995). Methods usedto gather data, as suggested by Witkin and Altschuld(1995), include archival material, communication pro-cesses, and analytic processes. According to thisframework, the residency program evaluation integrat-ed information from a number of sources using varyingmethods to assess program effectiveness and developplans for improvement.

Archival material such as employment records canbe accessed for demographic data and trends in



FIGURE1 Harborview Medical Center/Patient Care Services Nursing Clinical Orientation Evaluation. Used with permission.



recruitment and retention. This can be specific toparticular nursing units to focus on their issues andindicators of success.

The communicative processes of evaluation werecarried out with the target group, the new graduatesthemselves, to get information and opinions from theirperspective. An effective survey asks for informedopinions based on personal experience (Witkin &Altschuld, 1995). Three components evaluated variousparts of the program: their experience with their

preceptor, unit integration, and the evaluation of theprogram as a whole (see Figure 2).

A survey was developed and distributed to assess thequality of the preceptorship. Each participant was giventwo surveys to complete on their choice of preceptorswho had the most influence in their orientation. Acategory scale of preceptor behaviors and learning sit-uations was developed to determine the strength orpreceptor competency and learning situations, as wellas an objective means for analysis and feedback.

FIGURE 2 Harborview Medical Center/Residency Program Evaluation Tool. Used with permission.



Information on unit integration was obtained from abrief survey soliciting feedback and was analyzed toassess the learning environment and involvement ofthe staff as factors in socialization.

The third component of the survey evaluated thecourse components, as well as an evaluation of thecourse coordinator or nurse educator, and was pro-vided from all three groups: nurse graduates, precep-tors, and managers.

An interactive assessment was performed as wellwith the new graduates. At the end of the coursewhen participants were perceived to be more com-fortable and open to expressing themselves, a group

process was conducted. Discussions between the newgraduates and the clinical educators took place toidentify those program components that were effectiveand those aspects of the program that could beimproved. Together, the graduates and clinical educa-tors formulated changes in the program to contendwith problem areas that were identified.

Debriefing sessions and group forums with precep-tors are valuable for sharing information and experi-ences, identifying issues and potential solutions forchange, and enhancing the network among thepreceptors and educators. A survey that evaluatesthe preceptors was requested and proposed by the

FIGURE 2 (Continued)



preceptors through an open forum. The preceptorswere instrumental in the development of the tool.

Respondents, or those who can provide additionalinformation about the program, were identified as thepreceptors and nurse managers. Discussions were heldwith both groups to solicit feedback and ideas forimprovement.

Combining input from these various perspectivesoffers a broad view to assess program effectiveness.This approach of participatory evaluation, as describedby Fink (1993) and others, can augment meaning,

support, and investment of those involved in theprogram. Program changes were initiated and based onthe program evaluation and included an additionalclassroom day, modification of the expected timeframes for completion of orientation, and strategiesfor ongoing preceptor support.

SUMMARY

Nurses who are new to the profession benefit fromspecialty orientation programs during the transition

FIGURE 2 (Continued)



from student to nurse status. Understanding of theskill level of advanced beginners and the growth that isgained from experience can guide the programcomponents of a specialty orientation program. Thepreceptor model has been found useful for integratingnew nurses and for reciprocal learning and growth ofexperienced nursing staff. Awareness of expectationsfrom both the employer’s and graduate nurse’s pointsof view enhances the effectiveness of orientation andleads to a tailored orientation that supports the neworientee, as well as benefits the employing institution.Several strategies for providing active learning experi-ences in a safe and stimulating environment areoffered. The educational goals of specialty orientationprograms are to encourage creative thinking, fosterintegration into the system and nursing profession,and promote the skills of lifelong learning.

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CA: Sage.

ADDRESS FOR REPRINTS: Joan Santucci, MN, RN, ONC,Harborview Medical Center, Clinical Education 359733,325 Ninth Avenue, Seattle, WA 98104 (e-mail: [email protected]).

STATEMENT OF OWNERSHIP, MANAGEMENT, AND CIRCULATION (Act of August 12, 1970; Section 3685;Title 39 United States Code) Date of Filing–October 1, 2004. Title of Publication–Journal for Nurses in StaffDevelopment; Frequency of Issue–Bimonthly; Annual Subscription Price–$89.00; Location of Known Office ofPublication–Lippincott Williams & Wilkins, Inc., 16522 Hunters Green Parkway, Hagerstown, MD 21740-2116;Location of the Headquarters or General Business Offices of the Publisher–Lippincott Williams & Wilkins,Inc., 530 Walnut Street, Philadelphia, PA 19106; Publisher–Lippincott Williams & Wilkins, Inc., 530 WalnutStreet, Philadelphia, PA 19106; Editor–Belinda E. Peutz, PhD, RN, 7794 Grow Drive, Pensacola, FL 35214;Managing Editor–Randi Davis, Lippincott Williams & Wilkins, 530 Walnut Street, Philadelphia, PA 19106;Owner–Lippincott Williams & Wilkins, Inc., 530 Walnut Street, Philadelphia, PA 19106, 351 West CamdenStreet, Baltimore, MD 21201; Wolters Kluwer, US, 333 Seventh Avenue, New York, NY 10001; Wolters Kluwernv (owns 100% of stock), Stadouderskade 1, 1054 FS Amsterdam, The Netherlands; Known Bond Holders,Mortgagees, and other security holders owning or holding 1 percent or more of the total amount of bonds,mortgages, or other securities–None. A. Total no. of copies printed (net press run), average–5,475, actual–5,700. B. Paid and/or requested circulation 1. Paid/requested outside-county mail subscriptions stated onform 3541, average–4,040, actual–3,751; 2. Paid in-county subscriptions, none; 3. Sales through dealers andcarriers, street vendors, counter sales, and other non-USPS paid distribution, average–203, actual–217; 4.Other classes mailed through the USPS, none. C. Total paid and/or requested circulation [sum of B (1), (2),(3), and (4)], average–4,243, actual–3,968. D. Free distribution by mail (samples, complimentary, and otherfree), 1. Outside-county as stated on form 3541, average–96, actual–314; 2. In-county as stated on form 3541,none; 3. Other classes mailed through the USPS, none. E. Free distribution outside the mail (carriers or othermeans), average–19, actual–29. F. Total free distribution (sum of D and E), average–115, actual–343. G. Totaldistribution (sum of C and F), average–4,358, actual–4,311. H. Copies not distributed, average–1,117, actual–1,389. I. Total (sum of G and H), average–5,475, actual–5,700. Percent paid and/or requested circulation,average–97.36%, actual–92.04%. I certify that the statements made by me above are correct and complete.Jeffrey Brown, Manager, Periodicals Operations.



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