• 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.

• 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 equivant period of supervision if sequential collaborative MDs exist.

• Request that the attestation form be a simple check box of 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.