Thank you for the opportunity to provide public comment. I have been a nurse practitioner (NP) for 20 years practicing in a variety of settings in Virginia and overseas.  Completion of graduate education and national board certification deem that I am a competent clinician. As a small business owner in a solo NP practice, implementing the following requirements places a financial burden and hardship on the business as well as barriers to growing the practice and providing patient care.

 Please keep this in mind as rules are being promulgated.

• The five-year equivalent requirement creates a costly bottleneck to building provider workforce and equitable distribution in primary care delivery for underserved and vulnerable populations. Unduly burdensome regulations on top of this requirement will result in additional bottlenecks compromising access to care. 

• NPs already pay fees associated with RN, NP, and prescribing licenses and if they are business owners, pay fees to collaborating physicians. Any additional fees associated with submission of attestation and issuance of autonomous designation should not 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. Office administrators, health system administrators, and credentialing documents should all 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.

• NPs in any state or working for U.S. Armed Forces, U.S. Veterans Administration or the Public Health Service should be able to submit evidence that the five-year full-time equivalent collaborative requirements have been met with signature from employer, physician, practice administrator, etc.

• 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.”

• Both the NP and the patient care team physician should be held to disciplinary standards for providing falsified documentation to the Boards.

Thank you,

Nurse Practitioner Buky