The proposed change does not recognize the critical care transport nursing specialty within the scope nursing practices. With a lack of a critical care interfacility regulation and the over simplification that a critical care transport nurse hold an EMS certification will only further complicate credentialing of the "employed provider" i.e. critical care transport nurse.

The Board of Nursing position statement should mimic the best practices that are authored by the accrediting nursing agencies / Air & Surface Transport Nurse Association (ASTNA) & Accreditation of Medical Transport Systems (CAMTS) which is the recognized specialty of advance scope of practice for critical transport nurses as "employed providers" when working for a health system that holds an EMS agency number .

Agree with Mr. Riley regarding the oversimplification and unnecessary steps to ensure the best use of employed transport nurses in the the environment for which they have been specifically trained, evaluated, and approved to practice by their physician medical director. Great efforts have already been made by medical transport industry experts. ASTNA and CAMTS guidelines would far better serve the Virginia Board of Nursing as the foundation for their statement on the matter.

Agree with the prior comments.  

The proposed change creates unnecessary hurdles for critical care transport nurses employed by EMS agencies and undermines the strides made over the last two decades to recognize and standardize best practices by agencies such as the Commission on Accreditation of Medical Transport Systems (CAMTS) and the Air & Surface Transport Nurses Association (ASTNA). 

The Air & Surface Transport Nurses Association (ASTNA) position statement on the role of RN’s in the out of hospital transport environment is the industry standard and should be used as a model for best practice in the state by the Virginia Board of Nursing.  Flight nurses, critical care ground transport nurses, and neonatal-pediatric teams across the state need to be recognized for the nursing contributions to patient safety and quality they can make outside of healthcare facility walls.      

Any proposed changes should include a carve out for critical care transport nurses,  employed by the agency, with documented training, education, and certification in the prehospital/transport environment to allow them to function as nurses under the agency license and under the supervision of the agency medical director.

Respectfully submitted.