As practicing Clinical Nurse Specialist in Virginia with a focus on Wound, Ostomy, and Continence disorders, I ask the BON to reject the petition set forth by Ms. Hurley to substitute additional clinical hours for a certification examination. As you know, there is a national endeavor underway, captured in the IOM Future of Nursing Report to standardize advanced practice nursing.  This effort is clearly needed to address not only the needs of our Commonwealth but the nation in providing access to quality health care and improved patient outcomes.  The Clinical Nurse Specialist is both educated and certified to provide expert nursing care through a rigorous graduate level program and post-program certification examination.  The national effort supports this standard, establishing licensure as an APRN for all APN roles as the first standard to protect the public and certification to validate expertise at this level of nursing practice. I ask the BON to reject this petition and maintain the current certification requirement, while continuing to support specialty certification through National Specialty Nursing Organizations for expanded practice specialties.