Thank you for the opportunity to provide public comment. I have been a nurse practitioner (NP) student who will be graduating soon.
I am writing to ask that you minimize the regulatory burden associated with the attestation of practice in to order to avoid what could become a bottleneck compromising access to care.
NPs already pay fees associated with RN, NP, and prescribing licenses. Any additional fees associated with submission of attestation and issuance of autonomous designation have the potential to create a financial barrier for qualified NPs to practice.
Acceptance of “other evidence” demonstrating that the applicant has met the requirements must be broadly interpreted. We ask that the Joint boards issue a guidance document listing examples of supporting evidence that they would take into consideration. For example, administrative and credentialing documents should be accepted as evidence that an applicant has met the necessary requirements.
The Boards should credit applicants by endorsement for all of their time employed and licensed in other states towards calculating their clinical experience requirement for practicing without a practice agreement.
There is no demonstrated need for additional requirements on the attestation in order to protect the public beyond what is listed in HB 793. The attestation should be used to document clinical experience under a sworn statement that this information is accurate and meets the requirements of the law.
Most, if not all, states requiring attestation of transitional clinical hours are not overly prescriptive in what they require in their regulations or on their attestation forms. Therefore, in Virginia it should not be necessary to further define what is meant by “the patient care team physician routinely practiced with a patient population and in a practice area included within the category for which the nurse practitioner was certified and licensed.”
Thank you for consideration of my comments and for supporting expanded access to care.