As a member of the Virginia Association of Clinical Nurse Specialists and practicing Clinical Nurse Specialist, I do not support the petition set forth by Ms. Hurley to substitute additional clinical hours for a certification examination. The petition is not consistent with the recomendations set forth by the IOM Future of Nursing report and the Consensus Model for APRN Nursing practice, which address national standards for Licensure, Acreditation, Certification and Education of APRNs. The Hurley petition would lead to fragmentation of national standards and is not supported by best evidence.  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.  Therefore, I ask the BON to reject this petition and maintain the current certification requirement.