There appears to be a shortage of available clinicians in the Commonwealth to provide healthcare services. It is strongly in the public interest to allow and promote qualified practitioners to manage patients independently without restrictions. Cumbersome requirements for practice only serve to inhibit access to care. Maryland and DC allow independent practice. There is no compelling reason why Virginia cannot do the same. Requiring by law, collaborative practice severely limits the ability of NPs to start businesses, thereby limiting public access especially in underserved areas.

Regulations should clarify that autonomous practice means that NPs are not required as routine practice to collaborate/consult. Also, requiring physician collaboration reduces efficiency of the physician.

The numbers 5 years and 8000 hours should be reduced, even most physician residencies are shorter.

The wording of “1600 hours per year” and "full-time clinical experience" should be eliminated. Very simply, a certain number of hours can be required (without any mention of full-time or 5 years). For example, 4000 hours could be required. No mention of full time needed. (What if a NP works part-time for 10 years? Is this equivalent?)

Re: autonomous practice by endorsement (90-30-86 Subsection F) makes reference to subsection A. NPs originally practicing in states that allow full independent practice may not be able to meet requirement A2 (of 90-30-86 section A) because they may have been practicing for years in a state that does not require a physician practice agreement.

A physician may be unwilling to sign an attestation for self-serving business reasons despite the NP meeting requirements. Therefore, the documentation burden should be light for an NP providing documentation of hours worked.

Eliminate 90-30-86 subsection G.2 as this can be construed to require collaboration on every case.