Public Comment on 18 VAC 90?30

Regulations Governing the Licensure of Advanced Practice Registered Nurses

Comment

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 safety, economic impact, and regulatory clarity as they relate to CNS practice.

Public Health and Safety:
CNSs are graduate?educated, nationally certified APRNs who provide high?quality, evidence?based care within defined populations and specialties. Regulations should continue to protect public health while recognizing CNS education, training, and competencies. Requirements that do not meaningfully improve patient safety unnecessarily limit access to care, particularly in specialty and underserved settings. The population I care for, those living with diabetes, need an APRN-CNS who is trained and certified to care for them while they are hospitalized without barriers to independent practice.  

Economic Impact and Regulatory Burden:
Duplicative or prolonged supervision and joint regulation by both the Board of Nursing and the Board of Medicine imposes avoidable administrative and financial burdens without clear benefit. Streamlined, nurse?led regulation supports workforce stability, employer efficiency, and patient access while maintaining safety standards.

Clarity and Readability:
Clear, CNS?specific regulatory language would improve understanding and compliance. Greater consistency between 18 VAC 90?30 and 18 VAC 90?40, particularly regarding prescriptive authority, would reduce confusion and support effective implementation.

Structured Pathway to Independent Practice (SB 811):
A defined, time?limited transition period—such as the proposed 1,000 supervised hours—may be reasonable if it is competency?based, recognizes prior experience, and allows supervision by experienced prescribing CNSs or physicians. Clear criteria for completion and progression to independent practice are essential.

Conclusion

I respectfully urge the Department of Health Professions and the Board of Nursing to modernize CNS?related regulations by reducing unnecessary burden, clarifying requirements, and supporting a fair, competency?based pathway to independent practice while maintaining patient safety.