I am a Virginia?licensed Advanced Practice Registered Nurse (APRN)–Clinical Nurse Specialist (CNS) and appreciate the opportunity to comment on the periodic review of 18 VAC 90?30 pursuant to Executive Order 19. My comments address public health and safety, economic impact, and regulatory clarity as they relate to CNS practice within hospital?based pressure injury prevention programs.

Public Health and Safety:
Wound Care Clinical Nurse Specialists play a critical role in hospital?based pressure injury prevention through risk assessment, staff education, protocol development, product evaluation, and oversight of prevention and early intervention strategies. CNS?led programs are central to reducing hospital?acquired pressure injuries (HAPIs), improving patient outcomes, and supporting evidence?based practice. Regulations should protect patient safety while recognizing CNS advanced education, specialty certification, and clinical leadership. The role of CNS specifically focuses on secondary prevention and chronic disease management. The CNS role was specifically designed to improve patient outcomes that are impacted by NURSING interventions. Requirements that do not add clear safety benefit delay prevention efforts and consultation.

Economic Impact and Regulatory Burden:
Pressure injuries are associated with increased length of stay, higher treatment costs, and negative quality outcomes. Regulatory barriers that delay or limit CNS practice—such as duplicative supervision or joint regulation by the Board of Nursing and Board of Medicine— undermine prevention efforts and increase avoidable costs. Streamlined, nurse?led regulation supports efficiency and high?value care.

Clarity and Structured Practice Pathways:
Clear, CNS?specific regulatory language and alignment between 18 VAC 90?30 and 18 VAC 90?40, particularly regarding prescriptive authority, are essential. A defined, competency?based transition to independent practice is appropriate when prior inpatient and prevention experience is recognized.

Conclusion:
I urge modernization of APRN?related regulations to that will only serve to improve patient safety and financial burden across Virginia’s health systems.