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.

CNSs are graduate-educated, nationally certified APRNs who provide high-quality, evidence-based care within defined populations and specialties. 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.

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 pathway to independent practice that recognizes prior experience is appropriate. In it's landmark report, The Future of Nursing: Leading Change, Advancing Health, the Institute of Medicine recommended that nurses be able to practice to the full extent of their education and skills. Regulatory actions should be managed exclusively by 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.