I do understand that some schools may have difficulty in finding clinical sites in Virginia. I do believe with some creativity it is possible to find clinical sites within the Commonwealth of Virginia. I believe it is important to Virginians to keep the future nursing workforce in Virginia.

As a Virginia Nurse for my entire 49 year career, I have had portions of my career where I was licensed and practiced in West Virginia, Maryland and The District of Columbia. Each jurisdiction has their own unique requirements and methods.

Virginia Nursing Schools are trained by the Virginia Board of Nursing to follow Virginia Requirements for Nursing. I am also concerned that some jurisdictions do not have "Multi-state" licensure as part of the Nursing Compact. Examples of this is The District of Columbia and Pennsylvania. This is an indicator of differences in their processes which would trickle down to their training. Perhaps we should have "Member of the Nursing Compact" as a requirement.

With no milage limitation students could be sent to any US state or territory. The further the school is away from the practice site the more likely this would be a preceptor situation with infrequent faculty oversite. Perhaps we could consider a "contiguous jurisdiction" caveat.  This would require clinical sites to be in states that share a Virginia boarder. 

Additionally, there is no requirement that the school show any documentation that they have been approved by the other jurisdiction to practice there. With the current nursing shortages there has been a dramatic shift for my school. I have received requests from four new sites that want to affiliate as clinical partners as a recruitment tool. I do believe there should be a line that requires compliance with both the Commonwealth of Virginia Board of Nursing and the Board of Nursing for the jurisdiction clinical is located in.

Thank you for your time and consideration.

Janice Rayl, BSN, RN, CRNI

I agree that Nursing Programs in Virginia should not be limited to clinical hours outside of Virginia, especially if they are in range (50 miles) of the Nursing Program. For example  Sentara Albemarle Medical Center in Elizabeth City, North Carolina is 39 miles from our program in Chesapeake., Virginia. There is an increase in Nursing programs in Chesapeake and a decrease in available sites, this would resolve some clinical availability issues we currently are facing in Chesapeake, Virginia.

Please eliminate Clinical hours limitations outside of Virginia for Nursing Programs.

I support the removal of the limitation on the number of clinical education hours that may be obtained outside the state of Virginia. Educating nursing students in rural areas, particularly those located near state borders, presents significant challenges. Rural hospitals tend to be small, with limited services and fewer opportunities for exposure to complex patient care situations. In southwest Virginia, many patients requiring complex, tertiary, and specialized care must travel to hospitals just across the state line into Tennessee, Kentucky, and West Virginia. Additionally, the region's sole children's hospital and specialized pediatric services are located in Tennessee.

Exposure to a larger, more diverse patient population in high-volume, tertiary facilities with complex health conditions is essential for the clinical education of nursing students in rural areas. This experience helps students build the knowledge and skills needed for clinical practice, even if they ultimately work in smaller rural facilities within Virginia.

The current requirement of VBON Regulation 18VAC90-27-19, is burdensome for academic nursing programs, as it necessitates frequent submissions for approval each semester, despite the fact that the same challenges and solutions arise consistently. Given the unprecedented nursing shortage currently facing our nation and region, the ability to educate more nursing students is critical. The existing regulation restricts the ability to admit more nursing students due to the limitations on clinical education hours.

For these reasons, I respectfully urge the removal of the limitation on the number of clinical education hours that may be obtained outside of Virginia. We appreciate your continued efforts to create optimal clinical education opportunities for nursing programs in Virginia.

This would so be beneficial for many nursing schools as it is becoming more difficult to acquire good clinicals within certain ranges or those close to other states, facilities. 

I fully support the removal of the limitation on the number/percentage of clinical hours that must be conducted in Virginia.  This regulation has become a barrier to programs, faculty, and students especially if your clinical facilities in your service region are not only in Virginia, but Tennessee, Kentucky, and West Virginia.  Due to the nature of the Southwest Virginia region and changes to healthcare, services for pediatrics and specialty services may be accessed only in Tennessee or other states.  I support using Virginia facilities when it is feasible and makes sense to the education of our students, but that should be a decision based on a program's service region, healthcare services, proximity to other states, and availability of resources.  

The current requirement in regulation 18VAC90-27-19 has caused barriers for nursing programs.  It has reduced the program's ability to offer students a variety of hospital and clinical experiences especially within the Southwest Virginia region and other more rural locations in Virginia.  It also prevents increasing the number of students that a program can serve or accept into our nursing program.  It has also affected retention of part-time clinical faculty due to changes in reducing clinical experiences in TN and other states.

I know that program directors across the state have attempted to work within this regulation the best that they could, but I feel that it is urgent that this regulation is removed.  I believe it will benefit not only our students, but all of the clinical facilities within our region both in Virginia and adjoining students.  The need for nurses is great and we need to eliminate barriers to creating more nurses.

Please approval and remove the limitation on the number of clinical education hours that may be obtained outside of Virginia.  

Thank you for working to continue to improve nursing education in our state.

I am writing to support a change in the regulatory requirements for clinical hours in Virginia. Given our university's geographical location in the northern and western region of the state, the current regulation creates barriers to clinical sites within 50 miles of the bordering states of West Virginia, Maryland, and the District of Columbia. This limitation contributes to a decrease in the diversity of clinical experiences that may benefit nursing graduates' preparation for practice upon graduation. Clinical specialty areas already pose challenges, further exacerbated by state border limitations. 

Additionally, the current regulations contribute to the administrative burden in organizing and documenting student clinical experience and applying for exceptions each semester. 

I respectfully request support for a regulatory change that eliminates the limitations on out-of-state clinical hours. Thank you for your continued efforts to ensure quality education for nursing programs. 

I support the removal of the limitation on the number of clinical hours that must occur in Virginia. For educational institutions near state borders, removal of limitation allows students to gain greater access to clinical experiences that may provide more intricate and focused patient care found outside of the commonwealth. This opens the door to student learning experiences that may not be available in these smaller, more limited, rural healthcare settings. The ability for an educational institution to be able to offer a broader variety of clinical settings for their students is crucial in the development of new graduates who are better prepared and equipped to enter the healthcare arena with confidence and competence.     

I support this change because it will allow for more options for student living in Maryland to attend clinical in the area of potential practice.

Thank you!

I support the removal of limitations on clinicals outside of Virginia. Our program is in Abingdon, Va. We have one small hospital in Abingdon for clinicals and our larger hospital that can accommodate larger amounts of students is 16 miles from campus, but in Tennessee (compact state). The other Virginia hospital that is also 16 miles away does not have the patient census for an entire clinical group of 10 and another program uses this hospital for their clinicals.

This would relieve a major burden on our program as there are 8 or more nursing programs in our small area. 

Please vote to lift this restriction.

Thank you,

Jessica Jennings, NP-C

Hi,

As the Associate Dean of this nursing program I am in full support of this amendment to eliminate clinical hour limitations outside VA. We do have one main hospital system that we utilize for our program, but often find we are in competition with out of state schools and in state schools competing for time and units that we need. We have had to look outside of the state at times for other facilities and by eliminating the clinical hour limitations would be significant for our program.

Thank you

I believe there are benefits of eliminating clinical hours limitations outside of Virginia for Nursing programs by:

1. Increased Flexibility for Students: Nursing students can complete clinical hours in various states, providing greater access to diverse learning opportunities and accommodating their geographical preferences or life circumstances.

2. Broader Clinical Experience: Exposure to different healthcare settings, patient populations, and care practices enhances students’ clinical skills and cultural competence, making them more adaptable and well-rounded professionals.

3. Improved Accessibility: Removing restrictions allows students outside Virginia to pursue nursing programs without relocating, increasing enrollment opportunities and accessibility for a wider range of learners.

4. Enhanced Collaboration: Nursing programs can collaborate with a broader network of healthcare facilities nationwide, enriching clinical training quality and fostering innovative partnerships.

5. Eased Workforce Shortages: Streamlining clinical requirements can accelerate the preparation of nursing graduates, addressing workforce shortages more effectively, especially in underserved areas.

6. Alignment with Modern Education Models: Allowing remote or flexible clinical placements aligns with contemporary, technology-driven education models emphasizing competency over geographical constraints.

We fully support the proposed regulatory change. 

Educational institutions are eager to provide students with a variety of learning experiences, no matter their location, to develop quality nurses prepared to enter the workforce. This also has the potential to foster new collaborative partnerships between nursing schools/programs and healthcare systems in the bordering states.

The existing regulations create significant administrative challenges for nursing programs, requiring frequent submissions for approval that detract from the ability to educate nursing students amidst a continuing nursing shortage. In addition, the current regulations put an administrative burden on the BON requiring them to review exemption requests.

We appreciate the VA BON and their work to continue to support nursing programs in the state.

Thank you