Thank you for the opportunity to comment on regulatory process related to HB793. As a nurse practitioner with 21 years of experience, I am concerned with the overall implications of this legislation. It is well established that there is absolutely no evidence that any transition to practice period for certified nurse practitioners will improve quality of care or ensure safe practice. With passage of this compromise legislation, Virginia becomes an extreme outlier compared to other states with the longest transition period of 5 years full time practice. Additionally, the attestation process is fully dependent on the physician giving permission for the nurse practitioner to practice without an agreement, not on the nurse practitioner’s competence, and is overshadowed by perceived physician liability. After “transition” the NP must still, by law, consult and collaborate with other health care providers and establish a plan for referral of complex medical cases and emergencies to physicians or other appropriate health care providers. The Joint Board should consider that nurse practitioners are prepared by education and certification to practice, and these restrictions are unnecessary and a restraint of trade.

I would ask that the Joint Board consider the following in promulgation of regulations

1. The 5 year full time practice requirement should be fluid, allowing for nurse practitioners who have worked in a variety of settings during that time to combine years of practice.
2. The attestation document should be simple and not require a physician signature. Naming a physician(s) should be satisfactory. An audit process could satisfy this requirement. It should be established that a physician attestation does not imply liability and that a physician may not require payment for the attestation.
3. Nurse practitioners from out of state should, by the fact of licensure in another state for at least 5 years, qualify for the transition period without an attestation, as this creates an undue hardship and deters nurse practitioners from working in Virginia.
4. There should be a significant effort to collect data for the November 2021 report to the legislature, that will support a decrease in and/or removal of the transition period.