Thank you for the opportunity to provide public comment. I have been a nurse practitioner (NP) for 18 years practicing in acute, outpatient, geriatric and Integrative Medicine settings in the greater Richmond area. Completion of graduate education and national board certification deem that I am a competent clinician. Please keep this in mind as rules are being promulgated. I am board certified as an Adult Acute Care NP, but after working in an acute setting, mostly Cardiac Surgery at 2 hospitals in Ricmond for 8 years, I transitioned to outpatient in Gastroenterology, then Endocrinology. In 2010, I began an 2-year fellowship in Integrative Medicine at the University of Arizona. After completeion of that, I opened my own practice in Integrative Medicine, mostly managing chronic disease. I request that the requirement for "Routine practice in a practice area included within the category for which the NP was certified and licensed" be examined. As, I have 8 years of practice in the field in which I was board certified, that is not the area I'm practicing now. I am fully trained via a 2-year fellowship, as well as many other training programs and CME conferences, I would not want this bill to prohibit my ability to practice practice without a practice agreement with a patient care team physician. I would like consideration for NPs such as myself who have worked in other practice settings in which they are fully competent to do so. The regulations should not be written in a restrictive manner. 

Additionally, NPs already pay fees associated with RN, NP, and prescribing licenses. Any additional fees associated with submission of attestation and issuance of autonomous designation should not create a financial barrier for qualified NPs to practice. There is also no need for additional requirements on the attestation beyond what is listed in HB 793. It should be used to doucment clinical experience under a sworn statement and meets the requirments of the law. Both the NP and the patient care team physician should be appropriately disciplined for falsifying docments of attestation or other docments presented to the Board. 

Sincerely, 

Kristin Andrs, NP