Virginia Regulatory Town Hall
Department of Health Professions
Board of Nursing
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5/4/18  10:36 am
Commenter: Brittany K HInes

Recommendations for implementation of HB793

Thank you for providing the opportunity to offer suggestions for implementation of HP 793. For the requirement of attestation of practice. I would suggest the Nurse Practitioner is the only person required to sign for the attestation to practice.  This would require a one time fee for the designation. After the one time fee the standard license renewal will be sufficient. A 10% review of applications are randomly chosen to verify the five years of full time clinical experience. 


As for documents to verify 5 years of full time clinical practice. Written verification by a provider of employment, physician or Nurse Practitioner who has full practice authority including those practicing in an independent practice state/already met independent practice in the state of Virginia or a employers human resources department can be signed stating the amount of clinical experience specifically in hours.  I would suggest a fillable form be available for standardization that can be found of the board website. This verification can cover any amount of time. For salaried Nurse practitioners a contract with pay stubs can also be used to verify clinical experience. For Nurse practitioners that are hourly a contract with pay stubs showing number of hours practiced used. When using a contract and paystubs no signature is required by the physician, employer or practice representative. When using a contract and pay stubs a fillable form should be provided to allow Nurse Practitioners to calculate the exact hours of clinical experience and for standardization.  For Nurse Practitioners moving from an independent practice state that were in solo practice the license from the Independent state must be valid for 5 years with no additional requirements.  Nurse Practitioners applying by attestation should have these documents prepared to present at the request of the board.


The equivalence of five years could be simply calculated as 5years x 52 weeks x 40hours = 10,400 hours. This however does not take into account any paid time off that is used and could result in actuality a longer period of practice before a Nurse Practitioner is able to apply. If a Nurse Practitioner took only 2 weeks of vacation per year this totals a loss of 400hrs of clinical experience and an additional 10 weeks of supervised practice. 2 weeks is likely a underestiment of lost time. I request the board take into consideration Continuing education credits to also be applied to the clinical experience requirement. Continuing education credits provide ongoing learning and if often considered a part of the clinical experience. While in Nurse Practitioner school students gain valuable clinical experience. This student clinical experience and continuing education should also be valid to count as supervised hours and off set any lost clinical hours due to normal employment.


The way to determine hours should be very clear so Nurse Practitioners can accurately count hours prior to attestation to prevent accidental application. If a Nurse Practitioner is audited and found to not have sufficient hours, it should be brought to the board to determine accidental vs intentional falsification. If possible, I would suggest the option for a voluntary review prior to application with an additional charge separate from the attestation fee.


While ensuring public safety that Nurse Practitioners have fulfilled the 5 years of full time clinical experience. I ask when you are making decisions to put yourselves in the shoes of a applicants from different situations Nurse Practitioners moving to Virginia, experienced providers and new grads.

Thank you for the opportunity again.

Brittany K Hines,


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