May 2, 2018

To the members of the Committee of the Joint Boards of Nursing and Medicine and it’s Advisory Committee,

I am a nurse practitioner with 13 years experience. I am pleased with the passage of HB793 and the potential for release from the requirement of a collaboration agreement. I own my own practice in southern, central Virginia and in order to maintain a collaborative agreement, my physician collaborator and that of my colleague, expect to be paid for this service. This takes money away from the practice and the services we can offer. I am requesting an expedited process for the promulgation of these regulations so that we can obtain attestation and these funds can be retained in the practice. 

I ask that the fee for attestation be modest and the consideration of adding the letter “A” to the license number to designate those nurse practitioners who have completed attestation. The time frame to complete attestation should be limited to no more than 30 days from the date of the request to avoid delays in the process. The form should be simple, requiring only a check box and signature. The use of electronic signature such as with DocuSign should be considered in addtition to paper forms.

I would add that the skill set of a nurse practitioner has components that are common to any practice site such as taking a history, completing a physical exam and making a treatment plan that reflects current evidence-based guidelines. Therefore, a nurse practitioner with 5 years of experience could easily translate those skills to any setting and should be allowed to proceed with attestation even with a variety of practice sites or specialties during that five year period. Some states do not require that nurse practitioners have experience beyond certification to practice without a practice agreement and those that do, require much less time than Virginia has legislated.

In order to fill the need for health care providers in Virginia, we should readily accept the experience of nurse practitioners outside of the commonwealth for attestation. Some of our colleagues in Northern VA left the state to practice in nearby states and DC to be able to practice to the full scope of their education and training. We would hope to attract them back to Virginia with this new law to improve access to care.

Thank you for your consideration of these comments.

With regards,

Phyllis C Everett, NP-C

Owner, Sapient Health Services, PLLC dba Huddleston Health and Wellness