As president of the Virginia Association of Colleges of Nursing (VACN), I am writing on their behalf in opposition to the Petition for Rulemaking related to "Alternative to Clinical Hours for RN licensure." VACN is an organization of Virginia's 15 colleges and universities that offer baccalaureate and higher degree education programs for professional nursing.  One of the major purposes of VACN is to "Improve the practice of professional nursing through enhancing the quality of baccalaureate and higher degree nursing programs."

Scientific and research reports have provided evidence to support the need for a more highly qualified nursing workforce to meet the ever changing and increasingly complex health needs of the public and to provide safe and effective nursing care. The American Association of Colleges of Nursing has defined the essential competencies of baccalaureate and masters degree prepared nurses. To develop these competencies, students must participate in appropriate supervised clinical experiences.

Clinical experiences are essential for baccalaureate and higher degree nursing programs to prepare students to care for a variety of patients across the lifespan and across the continuum of care. In addition clinical experiences assist the graduate to:· develop proficiency in performing psychomotor skills? apply professional communication strategies to client and interprofessional interactions? and acquire a professional identity.

Thus, the Petition for Rulemaking related to "Alternative to Clinical Hours for RN Licensure" should not be approved. In doing so, one would remove a very important mechanism for ensuring competency and protecting the safety of consumers of health care.

Bennie L. Marshall, Ed.D., RN

President, VACN

Clinical practice opportunities expose students to practice issues such as technological innovations, accelerated care transitions, an unpredictable fastpaced environment, and complex system issues, which are all important in preparing the students for practice following graduation. In addition, clinical practice opportunities provide students with experiences and nursing role models that prepare them for practice in complex, changing healthcare environments.

Clinical learning is focused on developing and refining the knowledge and skills necessary to manage care as part of an interprofessional team. Nursing is a practice discipline. As such, during clinicals, theoretical learning becomes reality as students are coached to make connections between the standard case or situation that is presented in the classroom or laboratory setting and the constantly shifting reality of actual patient care.

Laboratory and simulation experiences provide an effective, safe environment for learning and applying the cognitive and performance skills needed for practice.  Although simulation experiences are an integral part of the armory for skill development, simulation experiences should augment clinical learning, not replace clinical learning.