Virginia Regulatory Town Hall
Department of Health Professions
Board of Nursing
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5/4/18  10:26 am
Commenter: Jennifer Shakesby McAdoo

Adoption of regulations for HB793

Boards of Medicine and Nursing,

I concur with my colleagues in respectfully requesting that the Joint Boards consider that the General Assembly overwhelmingly approved the fundamental concepts of nurse practitioner (NP) transition to practice with the five-year post-licensure compromise. Any interpretations that conflict with these fundamental concepts should be abstained from as they would be in opposition to the spirit of the legislation and bipartisan will of the General Assembly.

The NP community acknowledges that the five-year post-licensure transition to practice requirement resulted from political compromise and not evidence based facts.  Therefore, it is requested that the Joint Boards bear in mind that NPs have unique skills and expertise that are complimentary to the physician and other team members on the patient care team. It is not reasonable to expect that the physician's area of practice and the NPs licensure and certification would be identical. NPs work in many settings with MDs, DOs and DPMs, thus a broad interpretation of basic internal medicine education of any specialist physician must be considered sufficient to meet the requirement for practice in a patient population and practice area that the NP is licensed and certified.    

The board should also acknowledge the portability of professionals and that an NP may have had several collaborating physicians during the required 5-year transition period. As a result, the attestation form must accommodate the names of several physicians and/or other evidence from entities such as practice administrators, employers, or credentialing documents, etc. based on individual circumstances. It has been suggested and I fully support that the boards consider formatting the attestation as a check list for physicians to check the requirements specified in the law.  

For example:

  • physician has served with the NP pursuant on a practice agreement
  • physician routinely practiced with a patient population and practice area for which the NP is certified and licensed
  • physician practiced with NP from ____________date to ___________date

It is also suggested that the boards consider that NPs in any state or working for U.S. Armed Forces, U.S. Veterans Administration or the Public Health Service be able to submit evidence of the five-year equivalent post-licensure practice requirement with signature from an employer, a physician, a practice administrator, etc. when coming from another state to practice in Virginia. This will prevent obstacles to building the necessary provider workforce and equitable distribution in primary care delivery for underserved and vulnerable populations.

Thank you for considering my comments for the implementation of HB793.


Jennifer S. McAdoo, MSN, RN 

CommentID: 65294