I would oppose this proposal.  As mentioned here, this proposal is in complete disagreement with the current Consensus Model of Advanced Practice Nursing. This model is nationally recognized as the standard of practice for Advance Nursing Practice and certification.  In addition, it is currently recommended that a CNS be certified in a broader category such as Acute Adult and also carry a specialty certification that is pertinent to current practice.  Certification requirements and registration are clearly explained in current CNS education programs.   Allowing additional clinical hours to substitue for an actual certification exam, only weakens the designation and protected title of a Clnical Nurse Specialist in the Commonwealth of Virginia.  While I am sympathetic to Ms. Hurley's dilemma, there are options for her to sit for the Acute Adult certification exam and then proceed to take a specialy exam in her current practice area.  I would ask the BON to reject this petition and maintain the current regulation/certification standards.  The Commonwealth of Virginia should support the currently Consensus Model.