I am an advanced practice registered nurse - clinical nurse specialist (APRN-CNS) practicing in Virginia in a non-prescribing role focused on patient safety and the prevention of hospital-acquired conditions. I appreciate the opportunity to comment on the periodic review of 18 VAC 90-30.

Regulations should protect patient safety while recognizing APRN-CNS advanced education, national certification, and specialized expertise. Duplicative supervision or joint regulation delays CNS-led interventions without improving safety. CNSs have consistently demonstrated safe patient care and outcomes, are trained and educated by nurses, and as such, should be regulated by nurses rather than physicians. This model has been proven to be safe and effective in the majority of states.

CNSs who desire prescriptive authority should have a clear, structured pathway to independent practice following 1,000 hours of supervised practice by experienced prescribing CNSs or physicians. I respectfully urge modernization of APRN-related regulations to support safe, efficient, and effective patient care across Virginia.