Thank you for the comment period. Please reconsider the five year requirement [at least five years of full-time clinical experience]; it should be less than five years. Many APNs/Nurse Practitioners have considerably more years as registered nurses in practice as they enter graduate school and then exit school and successfully achieve certification. As a Professor in a graduate program preparing nurse practitioners I am well aware of their dedication to being the best practitioners, utilization of their prior skills as expert registered nurses, and expansion of their clinical reasoning and judgment abilities during their journey to certification. A five-year period will limit their ability to care for increasing numbers of individuals needing medical care and may stifle their innovation in developing new models of care delivery. Please consider solutions to aiding Virginia residents in seeking qualified professional care - one means is to facilitate the practice of experienced nurse practitioners.
Jennifer Matthews, PhD, RN, CNS, FAAN
Professor, Shenandoah University