As the President of the Virginia Council Of Nurse Practitioners, Northern Virginia Region, I represent over 300 member NPs. We are excited to now have an opportunity in Virginia to transition to practice for which we have been trained and certified. Here are some concepts to consider as you enact regulations to implement the bill.

• NPs have unique skills and expertise which are often complimentary to the physician and other team members and are not expected to be an exact overlay of the physician's area of practice.
•  
• NPs are prepared at the graduate level and are deemed competent clinicians upon graduation and passage of national certification. There is no evidence to support the need for additional post-licensure supervision of NPs’ practice beyond current educational and certification standards.

• The five-year post-licensure “transition to practice” requirement is the result of political compromise with no evidence to support the regulatory mandate.  This has created variability from state to state, making Virginia an outlier with the most arduous practice environment in the nation for NPs.

• The five-year requirement creates a costly bottleneck to building provider workforce and equitable distribution in primary care delivery for underserved and vulnerable populations. Unduly burdensome regulations on top of this requirement will result in additional bottlenecks compromising access to care.
•  
• The General Assembly overwhelmingly approved the central concept of transition to practice with the five year compromise. The Joint Boards should approach the regulatory process bearing this in mind and obstacles limiting those central concepts should be kept to a bare minimum as they are against the thrust of the legislation. Any overly strict interpretations suggested by those opposing the legislation would not be consistent with the spirit of the legislation and bipartisan will of General Assembly.

• Many NPs may have multiple team physicians during the transition period and there needs to be several signature lines for the physician. Each could specify the full time equivalent period of supervision if sequential collaborative MDs exist.

• Request that the attestation form be a simple as simple as possible, perhaps with check boxes re the requirements listed in the statute. For example:

[ ] Patient care team physician has served with the NP pursuant on a practice agreement

[ ] Patient care team physician routinely practiced with a patient population and practice area for which the NP is certified and licensed

• Request that office administrators, human resources department, health system administrators, credentialing documents, etc., may be used as other evidence.
•  
• Request that an NP in any state or working for U.S. Armed Forces, U.S. Veterans Administration or the Public Health Service submit evidence that the five-year full-time equivalent collaborative requirements have been met with signature from employer, physician, practice administrator, etc.

Respectfully submitted,

Valerie Wrobel, MSN, RN, AGNP-BC

President, Virginia Council of Nurse Practitioners, Northern Virginia Region.