As an advanced practice nurse (APN), I am highly concerned about the message this legislation sends to the public about the legitimacy and competency of all APN roles, not just nurse practitioners (NP). The medical community, with whom I have respectfully worked alongside for forty years, continues to demand all oversight of healthcare delivery. This mindset reflects the ongoing belief of our physician colleagues that medical practice encompasses the whole of healthcare, and pharmacists, physical therapists, dieticians and professional nurses (and other healthcare providers) require direction by physicians in order that patients receive appropriate care. The evidence does not substantiate this.

Healthcare is increasingly complex with no one discipline capable of “knowing” what each discipline has taken years of education and clinical experience to learn and henceforth, apply in the care of patients. There is mounting appreciation that interprofessional teamwork and patient-centered care are the most important components of our future healthcare system particularly for patients with multiple chronic conditions. The current effort to develop regulations needs to be undertaken in the spirit called for by multiple national bodies, i.e. the IOM’s “The Future of Nursing” Report, the Institute of Healthcare Improvement, the Joint Commission and numerous others. Let healthcare professionals provide the care they were educationally prepared to deliver. The time is now for true leadership in the commonwealth of Virginia in guiding the redesign of our healthcare system so patients receive the care they deserve.

I would challenge the Joint Boards to participate in these discussions in a manner that eliminates barriers to all advanced nursing practice, and in this case, permits NPs the autonomy to deliver primary care as they were educationally prepared. NPs, like all APNs, are deemed competent to provide nursing care through educational preparation, national licensing examinations and certifications. I would specifically request that clear lines of accountability be established in these regulations for our physician colleagues. There is significant risk for license censure when APN practice is tied to physician practice. APNs have been wrongly held accountable for unprofessional physician conduct (i.e. dereliction of duty, etc.) while the involved physician(s) were not concomitantly reprimanded by the Board of Medicine. This constitutes regulatory bullying, wherein the professional competence and reputation of APNs is damaged while the physician remains unscathed. Finally, the regulations should distinguish this type of workplace violence so that the instigators and facilitators of regulatory bullying may be held accountable. Let the regulations reflect a just practice environment.