In it's current form- the regulation doesn't clearly state if all conditions must be met or the individual must meet at least one to meet the regulation.  

The are several certifications available depending on the clinical area.  Can it be any related certification or any level - For example, lactation counselor or EFM for OB.  Any restrictions as to the awarding organization?

I would recommend that the Board provide additional guidance to define what constitutes an acceptable “certification in the specialty.” Clear, standardized criteria would ensure consistency and maintain the integrity of clinical instruction across programs.

I propose that acceptable certifications be those accredited by nationally recognized credentialing bodies such as those included under the Magnet Recognition Program®, including:

• The National Commission for Certifying Agencies (NCCA)

• The ANSI National Accreditation Board (ISO/IEC 17024)

• The Accreditation Board for Specialty Nursing Certification (ABSNC)

• The International Certification Accreditation Council (ICAC)

Aligning with these nationally established accreditation standards would provide a transparent, uniform framework while supporting the intent of the proposed regulatory change.

While clarifying faculty qualifications is important, limiting “alternative credentials” to certifications and recent clinical practice during a nation-wide nursing shortage is too restrictive. CNE certification requires a master’s degree, making it inaccessible to BSN-prepared faculty. Although CNEcl offers a pathway for BSN nurses, it still demands significant teaching experience, which many qualified bedside nurses lack.

Additionally, in the acute care setting, a BSN-prepared nurse maintains the same scope of practice as a ADN nurse.  Therefore, clinical faculty who are teaching pre-licensure nursing students in the acute care setting (whether ADN or BSN) should not require further education beyond what was required for them to pass the NCLEX.  Conversely, in community health settings, only BSN-prepared faculty members should instruct pre-licensure BSN-seeking nursing students due to the difference in scope of practice and educational preparedness.

The Board should prioritize clinical faculty with strong bedside experience over degrees and certifications. Expanding flexibility will help programs recruit competent nurse educators without compromising quality, ensuring Virginia meets the growing demand for nursing graduates.  

At the end of the day, I have never once had a patient ask me about my nursing degree.  My competence as an experienced bedside nurse speaks for itself. 

Thank you for considering this recommendation.

If the word "or" was included at the end of clause number 1, these new guidelines would make more sense to me.  Both clause 1 and 3 list credentials which require a graduate degree (MSN or higher) and/or significant additional experience, much like a graduate degree.  Without the word "or" before it, clause 2 doesn't make much sense because clause 2 is required for any nurse to meet the requirements of clause 1 or clause 3.

In the current nurse shortage and nurse-faculty shortage environment, we need to have more flexibility, not less, to hire BSN-prepared clinical faculty who have at least 2-years of experience in a particular clinical area to help us teach and graduate well-prepared bedside nurses.  Clause number 2 allows for that, but only if the word "or" appears at the end of clause 1.

The regulation refers to "clinical nursing faculty" alternative credentials. Does this change in education requirements include nursing learning laboratory faculty?

BSN clinical faculty needs to encompass the campus skills labs and the hospital clinical setting. BSN nurses are active practice and encompass current knowledge and skills that can be taught to the next generation of nurses. We are in a nursing shortage and I am happy to have BSN nurses in the clinical setting and the current guidelines need to support BSN nurses in the lab and clinical setting.

Lab is a hands on learning environment to ensure students are deemed competent to perform these skills in the clinical setting. This is not a didactic environment. Hands on learning that is taught to reinforce skills and safety in the direct patient care setting. BSN nurses have these skills to teach in the lab and lead into the clinical setting. Guidelines need revised to encompass this change.