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.

As a  doctoral-educated, nationally certified APRN, I provide high?quality, evidence?based care within the defined populations and specialties for which I am licensed. Regulations should protect public safety while recognizing CNS education, certification, and clinical expertise. Requirements that do not meaningfully improve patient safety, limit access to care, and increase unnecessary regulatory and economic burden.

CNS?specific regulatory language and alignment between 18 VAC 90?30 and 18 VAC 90?40  are essential. A defined pathway to independent practice that recognizes education and advanced healthcare experience is essential. In the 2021 DHP REPORT ON ADVANCED PRACTICE REGISTERED NURSES: 2021 BUDGET BILL, the following actions were supported:

i. Regulation of APRNs according to the National Council of State Boards of Nursing, which presents recommendations for state legislatures and boards regarding the regulatory structure for APRNs (Certified Nurse Practitioners, Certified Nurse Midwives, Clinical Nurse Specialists, and Certified Registered Nurse Anesthetists).

ii. Granting all APRNs the ability to practice independently,
iii. Regulate APRNs solely through the Board of Nursing, 
iv. Further recommendations from DHP are:  
       1) Amend statutory and regulatory definitions to conform to those in the APRN Consensus Model;
       2) Consider amending Virginia laws and regulations to align with the APRN Consensus Model; 
       3)  Follow The Future of Nursing: Leading Change, Advancing Health, the Institute of Medicine that recommends nurses practice to the full extent of their education and skills. under the Board of Nursing.

I respectfully urge modernization of APRN ?related regulations to support safe, efficient, and effective patient care across Virginia. APRNs are nurses and regulation should be wholly managed by nurses.