Virginia Regulatory Town Hall
Department of Health Professions
Board of Nursing
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5/2/18  2:47 pm
Commenter: Jennifer Fellman DNP, FNP-C

Attestation issues/concerns

I have worked as a NP for 13 years.  The last 4 of those years I owned my own house calls practice.  Unfortunately, I closed that practice in December due to excessive costs of running the business in relation to Medicare reimbursements. A major cost for me was paying a monthly fee for a collaborating physician.  I am very happy that we are in the process of reducing this barrier to practice, but as many know we still have a ways to go.  

I ask the boards to consider the inconvenience and expense (time and/or money) in chasing down former physician employers to sign a permission slip to allow experienced NPs to practice without a collaborative agreement. And to that, what are the requirements for the physician? Is it possible a physician would chose to not sign, not because the NP is incompetent, but that they don't want the liability of "vouching" for the NP. What exactly would the board ask the physician to attest to?  Is it a simple yes/no and signature?  What, if any, are the implications of the signing physician in the event the NP does violate standards of the profession?  One would not think this would be fair or reasonable.  However, the concern of some physicians is that it would imply liability for the NP just as many fear collaborating with NPs for the same reason (even though the law states otherwise). 

As another NP stated in comments earlier, the NP is the only person who should have to attest to their 5 years of experience.  If the board has reason to believe (or a complaint is filed) that a NP has falsified that attestation then a formal review/investigation would be appropriate and a better use of time and money for the joint boards. 

I thank you for the opportunity to comment on this issue. Please consider keeping this process as basic and paperless as possible.  

Jennifer Fellman DNP, FNP-C


CommentID: 65270