Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Nursing
 
chapter
Regulations of the Board of Nursing [18 VAC 90 ‑ 20]

23 comments

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3/1/13  2:35 pm
Commenter: Linda Thurby-Hay MS, RN, ANCS-BC, BC-ADM, VCU Health Systems

Do not support this remedy.
 

As President of the Virginia Association of Clinical Nurse Specialists, I do not support the remedy before the BON in the petition set forth by Ms Hurley to substitute additional clinical hours for a certification examination.  There is a national endeavor underway, captured in the Consensus Model for Advanced Practice Nursing document, to standardize all aspects of Advanced Practice Nursing.  This effort is clearly needed to address not only the needs of our Commonwealth but the nation’s citizenry in providing access to quality health care and improved patient outcomes.  The Clinical Nurse Specialist is both educated & certified to provide expert nursing care through a rigorous graduate level program and post-program certification examination.  The national effort supports this standard, establishing licensure as an APRN for all APN roles as the first standard to protect the public and certification to validate expertise at this level of nursing practice. Although I sympathize with Ms Hurley’s inability to sit for a CNS certification examination in Women’s Health at this time, there is precedent for her to sit for the Adult Health Clinical Nurse Specialist certification exam.  There are also other possible options to validate her expertise, eg portfolio submission.  The national effort has been underway for several years and other states have grappled with this issue.  Hence, I would ask the BON to not accept additional clinical hours as a substitute for validated Clinical Nurse Specialist expertise.

CommentID: 26253
 

3/1/13  7:09 pm
Commenter: Phyllis Whitehead

Say No To This Petition
 

As an officer of the Virginia Association of Clinical Nurse Specialists, I ask the BON to reject the petition set forth by Ms. Hurley to substitute additional clinical hours for a certification examination. As you know, there is a national endeavor underway, captured in the IOM Future of Nursing Report to standardize advanced practice nursing.  This effort is clearly needed to address not only the needs of our Commonwealth but the nation in providing access to quality health care and improved patient outcomes.  The Clinical Nurse Specialist is both educated and certified to provide expert nursing care through a rigorous graduate level program and post-program certification examination.  The national effort supports this standard, establishing licensure as an APRN for all APN roles as the first standard to protect the public and certification to validate expertise at this level of nursing practice. Therefore, I ask the BON to reject this petition and maintain the current certification requirement.

CommentID: 26258
 

3/2/13  6:39 am
Commenter: Jennifer Matthews, PhD, RN, A-CNS, CNE, FAAN Shenandoah University

Hurley Petition for CNS practice without certification examination
 

My CNS colleagues, VaCNS President Linda Thurby-Hay and Dr. Phyllis Whitehead, have provided strong arguments and identified policies at the national level which were crafted by nurse leaders from nearly 50 associations with interests in advanced practice nursing.  The work leading to the 2008 Consensus Statement (referenced by Thurby-Hay) was an open process in order that Schools of Nursing, Regulators, Certifying Agencies, and Employers would have sufficient lead time to develop appropriate plans to accommodate the anticipated changes and then, after 2008, the changes for the 2015 implementation.  I concur with and support the statements of Thurby-Hay and Whitehead that this appeal be denied.

CommentID: 26261
 

3/4/13  11:42 am
Commenter: Patrick Coyne

CNS Requirements
 

This is not consistent with the national movement to legitimize Advanced Nursing Practice as a whole and CNS's specifically.  The Consensus Model for Regulation of Advanced Nursing Practice clearly wants APN's to move toward licensure (not just registration) and substantiate this level of expertise through certification. I CLEARLY OPPOSE THIS !

CommentID: 26283
 

3/4/13  11:46 am
Commenter: Laura Savage RCNS

Oppose recommendation
 

Certification was developed as a consumer protection. It is also validates the practitioners knowledge. experience is important but I am opposed to the subsitution of time for a certfication exam,

CommentID: 26284
 

3/5/13  6:44 pm
Commenter: Mary Christine Schaeffer, VCU Health Systems

Opposition
 

I would oppose this proposal.  As mentioned here, this proposal is in complete disagreement with the current Consensus Model of Advanced Practice Nursing. This model is nationally recognized as the standard of practice for Advance Nursing Practice and certification.  In addition, it is currently recommended that a CNS be certified in a broader category such as Acute Adult and also carry a specialty certification that is pertinent to current practice.  Certification requirements and registration are clearly explained in current CNS education programs.   Allowing additional clinical hours to substitue for an actual certification exam, only weakens the designation and protected title of a Clnical Nurse Specialist in the Commonwealth of Virginia.  While I am sympathetic to Ms. Hurley's dilemma, there are options for her to sit for the Acute Adult certification exam and then proceed to take a specialy exam in her current practice area.  I would ask the BON to reject this petition and maintain the current regulation/certification standards.  The Commonwealth of Virginia should support the currently Consensus Model. 

CommentID: 26364
 

3/5/13  10:58 pm
Commenter: Kimberly D. Hall, DNP, RN, GCNS-BC, CWCN-AP

Oppose this Petition
 

As practicing Clinical Nurse Specialist in Virginia with a focus on Wound, Ostomy, and Continence disorders, I ask the BON to reject the petition set forth by Ms. Hurley to substitute additional clinical hours for a certification examination. As you know, there is a national endeavor underway, captured in the IOM Future of Nursing Report to standardize advanced practice nursing.  This effort is clearly needed to address not only the needs of our Commonwealth but the nation in providing access to quality health care and improved patient outcomes.  The Clinical Nurse Specialist is both educated and certified to provide expert nursing care through a rigorous graduate level program and post-program certification examination.  The national effort supports this standard, establishing licensure as an APRN for all APN roles as the first standard to protect the public and certification to validate expertise at this level of nursing practice. I ask the BON to reject this petition and maintain the current certification requirement, while continuing to support specialty certification through National Specialty Nursing Organizations for expanded practice specialties.

CommentID: 26388
 

3/6/13  9:03 am
Commenter: Donna Miller, BSN, RN, MSA

Requirement for registration as a clinical nurse specialist
 

CommentID: 26401
 

3/6/13  9:48 am
Commenter: Donna Washburn MSN, RN, CNS, ACNS-BC, AOCNS

Please say "No" to this petition
 

In light of the fact that Clinical Nurse Specialists are often called upon to address complex cases within a specialty; and in light of the fact that these complex cases often involve body systems and problems not immediately associated with an individual specialty, such as the multisystem effects of poor lifestyle choices, I would like to encourage the BON to continue to require a standard of completing the Adult CNS exam if there is  not an acceptable exam in the specialty.

As an Oncology nurse I successfully completed the Adult CNS exam after earning my Master's in Nursing and found it to be a good examination of the diverse knowledge that a caregiver of adult patients would need starting out as a Clinical Nurse Specialist in any specialty. One year later I also successfully  completed an oncology specific exam with the Oncology Nursing Certification Corporation.

I feel that testing for initial certification as a new graduate is our best method for evaluating the basic knowledge needed to perform safe care of our public. Clinical time is important, but in my opinion is not a subsitute for evaluation of this important basic knowledge requirement by the state accrediting body.

 

CommentID: 26408
 

3/6/13  1:02 pm
Commenter: Donna Miller, BSN,RN,MSA

Requirements for registration as a clinical nurse specialist
 

Regarding the APRN Consensus model and the certification requirement:

- Regulation that requires a CNS to be certified by examination as a CNS in

his/her specialty when there is no such exam is a major barrier and denies

the public access to CNS practice

- National Association of Clinical Nurse Specialists, 2005

- Requiring CNSs in these specialties to take what is termed as a "related

exam", such as ANCC's CNS Medical/Surgical exam, does not demonstrate

specialty knowledge and begs the question of the existence of such a

requirement for public safety reasons.- NACNS, 2005

-A core examination was developed by ANCC and NACNS. This examination was

offered twice and was well received by the CNS community. This examination

provided an option for the CNS to certify based on components of the CNS

role. Due to a number of factors, this examination is no longer available

and will not be available in the near future. -NACNS 2012

-NACNS has received reports from CNS's currently practicing in the role,

that some employers, in anticipation of the adoption of the Consensus Model

regulatory framework in their states, are eliminating CNSs that have not

obtained certification for APRN practice: despite the fact that such

certification examinations may be unavailable. -NACNS 2012

Precedence:

-Existing precedence of Perinatal CNS successfully certified via the CORE

Examination, denied registration by the Virginia State Board.

Due to the lack of a Womens Health CNS certification exam, Ms. Hurley's alternative solution appears to be reasonable, until such time as an exam is made available. I am in support of her petition. 

 

CommentID: 26423
 

3/6/13  2:30 pm
Commenter: Linda Jenkins, MSN, RN-BC, ACNS-BC

Oppose this Petition
 

This proposal is not in alignment with the Consensus Model for APRN Regulation which addresses licensure, accreditation, certification and education.  As we move forward with a national plan, accepting this petition would be a step backwards for Virginia APRNs. Please do not accept this petition.

CommentID: 26429
 

3/6/13  3:16 pm
Commenter: Victoria F. Mclean MSN, RN CCRN, ACNS-BC

please do not accept this proposal
 

To the point please say no to the petition as it is counter to the Consensus Model for APRN .  A certification in your specialty with the Adult Care CNS certification provides a well rounded support for practice. Hours of practice within a specialty will not reflect the understanding of all aspects of the CNS practice.

CommentID: 26434
 

3/6/13  11:10 pm
Commenter: Ellen M. Harvey DNP, RN, CCRN

Reject Hurley Petition
 

As a member of the Virginia Association of Clinical Nurse Specialists and practicing Clinical Nurse Specialist, I do not support the petition set forth by Ms. Hurley to substitute additional clinical hours for a certification examination. The petition is not consistent with the recomendations set forth by the IOM Future of Nursing report and the Consensus Model for APRN Nursing practice, which address national standards for Licensure, Acreditation, Certification and Education of APRNs. The Hurley petition would lead to fragmentation of national standards and is not supported by best evidence.  The Clinical Nurse Specialist is both educated and certified to provide expert nursing care through a rigorous graduate level program and post-program certification examination.  Therefore, I ask the BON to reject this petition and maintain the current certification requirement.

CommentID: 26453
 

3/12/13  8:56 pm
Commenter: Lucy A Smith RN MS CNS PMHCNS-BC, Fortis College and Private Practice

In opposition to Hurley petition
 

 I add my oppposition to the Hurley petition to substitute additional clinical hours for a certification examination.   I have been credentialed by the Virginia Board of Nursing as a CNS since 1990. I currently serve as  the dean of a nursing education program  in the Commonwealth and practice clinically as a PMHCNS.  I support  the rationale of  those who have previously commented in opposition and offer the following additional rationle for consideration.  Designating  2000 hours of clnical practice  as the measure of ensuring sufficient expertise for initial designation as a  CNS is problematic because practice hours alone are  not  reliable valid objective measures to ensure initial competence and expertise.   The petition also does not address the issue of  how continued competence over time would be measured and verified in the absence of national specialty certification.

CommentID: 26541
 

3/17/13  11:08 pm
Commenter: Jill M. Maldarelli-Drey MHR, MSN, RNC-MNN, CNS-BC

IN SUPPORT OF THE HURLEY PETITION
 

                I am in support of the Hurley petition as an interim solution until a specialty specific board certification exam is in place.  For your consideration, I respectfully submit my experience in attempting to gain APRN licensure in the state of VA.  In 2010, after having graduated from a CCNE accredited program, I carefully reviewed the VA BON website and proudly applied for APRN licensure.  I was alerted by mail that my application was denied.  When I called the BON to inquire as to why, I spoke with the BON president who informed me that it was due to not having specialty specific board certification.  At that time, nowhere on the BON website did it state this requirement.  I had however taken and passed the only examination made available to me, the ANCC CNS Core, which has since been retired.  Not only was I denied said licensure, the BON refused to refund my application fee, but instead applied it to my RN licensure renewal which added insult to injury.  I was a due paying member of the NACNS and reached out the president, however I received no support.  Needless to say, I am no longer a dues paying member.  I was left with no option for which to obtain APRN licensure in the state of VA and am to this day only licensed as an RN. 

                I urge my colleagues who oppose the Hurley petition to consider the perhaps hundreds of the masters prepared nurses with years of specialty specific experience in the field of women’s health and perinatal nursing who are not able to gain licensure  as APRNs.  Instead of presenting a unified front that supports all advanced practice nurses, our women’s health and perinatal subject matter experts are being left behind!  Not being eligible for APRN licensure not only limits options for employment and earning potential for the individuals themselves, but also weakens the community of advanced practice nurses as they are being excluded to no fault of their own.  Until a specialty specific exam is offered by AWHONN, ANCC, or NCC, these nurses should be given the opportunity in which to become licensed as an APRN as suggested by Hurley.  Once an exam is available, I confidently postulate that these nurses will proudly take the exam in order to be in compliance with the “national effort” and APRN consensus model.  With regard to the option proposed by some, indicating that women’s health/perinatal nursing CNSs have the option of taking the adult health exam.  I am professionally insulted by this and do not believe this to be a viable solution.  An adult health exam is in no way representative of the specialty and is just as bad, if not worse that having no specialty specific exam at all.  Thank you for your consideration and support of the Hurley proposal.

CommentID: 26621
 

3/18/13  6:29 pm
Commenter: Jean Ellen Zavertnik DNP, RN, ACNS-BC, CNE Virginia Commonwealth Univ.

Do not support the petition
 

I do not support the petition set forth by Ms. Hurley to substitue additional clinical hours as a substitute for the CNS certification examination. As a faculty at a state university, I beleive the Clinical Nurse Specialist is both educated and certified to provide expert nursing care through a rigorous graduate level program and post-program certification examination.   The Consensus Model for Advanced Practice Nursing document supports establishing licensure as an APRN for all APN roles as the first standard to protect the public and certification to validate expertise at this level of nursing practice.  Allowing additional clinical hours to substitue for an certification exam weakens the designation and protected title of a Clnical Nurse Specialist in the Commonwealth of Virginia.  

CommentID: 26634
 

3/19/13  2:48 pm
Commenter: Sheila B. Delp, Carilion Clinic

I do not support this petition
 

CommentID: 26652
 

3/20/13  2:22 pm
Commenter: Donna Bond DNP, RN, CCNS Carilion Clinic

Oppose this Change
 

The change is a step backwards for CNSs. This proposed change does not follow the LACE recommendations or the Consensus Model.  As a group, the CNSs need to work towards the Consensus Model and LACE recomendations.  It would be easier if there was a listing of approved tests for the CNS. There is a list on the NP site. If this person meets the education and clinical hours the Adult Health exam is appropriate.  It is very expense and time consuming for specialist groups to provided certification for each specialist.  My recommendation is this person take a broader exam, then obtain more specific certification if available (for example I have my CCNS AND Asthma Educator AND Certified Tobacco Treatment Specialist.). The CCNS is recognized by the state, the others are for my personal focus.      

CommentID: 26661
 

3/21/13  9:58 am
Commenter: Linda Thurby-Hay MS, RN, ACNS-BC, BC-ADM, CDE

Clinical Nurse Specialist
 

It is clear that the Consensus Model for APRN Regulation is driving this issue.  I graduated from the MS program in the CNS track at VCU with a focus in Med-Surg Nursing in 1988.  The population was adults so I was educationally prepared to sit for the Med-Surg (now called the Adult Health) exam and continue to hold that credential.  During my educational program, I was expected to develop advanced knowledge and skill in a subspecialty; my sub-specialty was in endocrine nursing.  As there was no sub-specialty exam for the Advanced Practice Nurse at that time, I later sought the Certified Diabetes Educator credential which validates the educative component of diabetes nursing.  It was only recently that an Advanced Practice Nursing credential in my sub-specialty became available, eg Advanced Diabetes Manager BC-ADM.  I then sought that credential.

NACNS fought to make sure Clinical Nurse Specialists were included in the conversation regarding who was an Advanced Practice Nurse, as initially we were not included.  Subsequently, NCSBN created a more inclusive model. The Clinical Nurse Specialist role remains unique.  Standardizing educational curriculums across the country so we can move throughout the US and still practice to the fullest extent of our education and skill is vital.  Standardizing licensure & certification is vitalPreserving the CNS role is imperative.  What we don't want to do is exclude ourselves from the ongoing conversation of what Advance Nursing Practice is.    

I have been in communication with Ms Hurley and have lead her back to her MS program contacts (who assured me she could pursue the Adult Health exam).  I have also put her in touch with a NACNS/AWHONN member who is actively involved in the work group developing the Core Competencies which will provide the foundation for a Women's Health exam.

CommentID: 26667
 

3/21/13  10:45 am
Commenter: Brenda Baker, VCUHS

Oppose Changes to Requirments for CNS
 

As a practicing CNS in Virginia I can not support a change in the requirements to practice as a CNS that allow for 2000 clinical hours as a substitute for a national certification exam. There is a national effort underway by our professional organizations to standardize requirements for all APN's. Straying from a national effort only adds confusion and dilutes our professional standard.

Additionally 2000 hours is little more than a year of full time work. To be an expert in a field requires more than a year of practice.

I ask the BON to reject this petition and maintain the current certification requirement.

CommentID: 26668
 

3/22/13  7:25 pm
Commenter: Tonnyann Hurley RN MSN

CNS Petition
 

I filed this petition not only for the Women's Health CNSs, but also for the Perinatal, Maternal-Child, Neonatal CNSs that in the Commonwealth of Virginia cannot receive recognition for completing the same Master's program as any Adult Health CNS throughout the country.  I requested an interim option, that is only applicable until a certification exam becomes available, as is being done in a number of states (eg. Maryland has an excellent option to the certification exam available to CNS practicing there). 

Further, the NACNS, on the website position statement (dated March 2012) that clearly supports the APRN Consensus model clearly recognizes that the certification requirement has eliminated the ability for many CNS to obtain state board recognition and in many cases employment. 

It is true that I was contacted by the president of the VaCNS and she did give some wonderful contact names.  However, the ANCC is very clear.  With a degree in Women's Health CNS, I do not qualify for the Adult Health CNS exam.  Additionally, the Virginia Board of Nursing requires the certification exam specialty to match the degree specialty, so it would be futile to take the adult health exam, even if it were possible.  I believe Women's Health is a viable specialty, not sub-specialty, and deserves an examination that specifically evaluates the knowledge of Women's Health CNS.

Finally, I do not support moving forward to achieve changes within the Commonwealth for CNSs without "bringing" all along.  It is great that there is work being done create an exam for the Women's Health CNS, but until that occurs another option needs to be made available. I support the APRN Consensus Model, but as we move toward it, how many are being left behind.

Please support a portfolio option for CNSs that meet all other requirements set forth by the APRN Consensus Model, as they are in existence, until specialty specific exams are available.  When the specialty examination is created, license renewal should require successful completion of the specialty specific certification exam.

CommentID: 26752
 

3/23/13  11:36 pm
Commenter: Kim Nelson MSN, RN-BC, ACNS-BC, CCRP, CCPC, RDCS

Do not support petition
 

I do not support clinical hours instead of board certification as qualification for registration as a CNS in Virginia.  I ask that the BON deny this request. This is not congruent with the Consensus Model for Advanced Practice Nursing and moves away from a standardization of CNS practice in the United States. The Virginia Association of Clinical Nurse Specialists and the National Association of Clinical Nurse Specialists along with various other groups are working to guide current practice into alignment with the Consensus Statement. Developing licensure requirements for Advanced Nursing Practice are underway and supported on a national level. I am involved with this process in my position as secretary of the Virginia Clinical Nurses Association. We will continue to bring forth the concerns of CNSs and advocate for CNSs to be permitted to practice to their full scope of training and education.

CommentID: 26818
 

3/24/13  9:44 pm
Commenter: Dale Mitchell, MS, RN, PCCN, ACNS-BC

Do not support this petition
 

I do not support this alternative for several reasons. First, this plan is not in agreement with the Consensus Model for Advanced Practice Nursing.  Also the number of hours in practice does not necessarily mean that the individual has the proficiency expected from a certified Clinical Nurse Specialist. Additionally, I would not support a petition that called for only a certification examination without clinical hours. Together, clinical hours along with an examination are currently the best ways to assess a sound clinical base of knowledge before one can use the title of Clinical Nurse Specialist.

CommentID: 26836