Virginia Regulatory Town Hall
Department of Health Professions
Board of Nursing
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5/2/18  7:17 pm
Commenter: Kimberly Marshall, AG-ACNP


Dear Board of Nursing and Board of Medicine: The attestation process should be broad and allow for other avenues in addition to physician declaration. There are many physicians who will not do this and their reasons will be plentiful including a presumed liability and feeling as if they are "releasing" an NP therefore implying that their "certification" on the attestation may imply a possible future liability. Consider that on each bi-annual license renewal, NPs, RNs, etc., already "attest" that they are meeting the continuing education requirements and there is no process for submitting documentation unless audited. A similar process could be done for attestation. Additionally, you could consider other records such as employment records from HR, etc. There are many NPs who have held multiple positions, changed jobs, have more than one job, etc., that will make gathering the "physician signature" a challenge that is against the current of this new law. The "equivanlent of 5 years full time practice" is HUGE, and when an NP finally meets that requirement, it is very likely that they would be able to support their own attestation by other means. The process of only having sworn statements by physicians is burdensome, and worrysome for both NPs and our colleague physicians. Thank you for the opportunity to express our concerns. 



CommentID: 65274