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Esteemed colleagues thank you for your consideration of public comment regarding the promulgation of HB 793.
Promulgating HB 793 will provide an excellent opportunity for Virginia to transition nearly 50% of licensed nurse practitioners to independent practice. This will increase access to care in our Commonwealth and is a demonstration of compromise between nursing and medicine.
The five year full time equivalence period is the longest in the nation; however, there are many examples of transitional licensing approaches in other states. Connecticut, Delaware, Maine, Maryland, Minnesota, South Dakota and Vermont all use a transition to independent practice model, however, none of these states require an attestation. Nebraska requires a transition to practice agreement for the first 2,000 hour of nurse practitioner practice; there is no mention of an attestation. New York allows transition after 3,600 hours at which time nurse practitioners attest that a collaborating physician is available to them. Virginia’s attestation requirement seems arduous; it would be a travesty to create an unbearable work burden for the Joint Boards.
The current nurse practitioner workforce in Virginia operates under collaborative agreements that are regulated by the Joint Boards. These collaborative agreements should be honored when considering the five year work equivalence. The boards should not have to redefine who is an acceptable collaborator simply because new legislation was passed. This creates unnecessary work and would unduly penalize our current workforce; thereby, defeating expansion of access to care. Therefore, it seems reasonable that the Joint Boards can create a simple attestation form that acknowledges the prior collaborative agreements between nurse practitioner and physician. The physician would simply verify that the nurse practitioner collaborated under the pre-existing contract for at least five years full time work equivalence.
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