Agree with the prior comments.  

The proposed change creates unnecessary hurdles for critical care transport nurses employed by EMS agencies and undermines the strides made over the last two decades to recognize and standardize best practices by agencies such as the Commission on Accreditation of Medical Transport Systems (CAMTS) and the Air & Surface Transport Nurses Association (ASTNA). 

The Air & Surface Transport Nurses Association (ASTNA) position statement on the role of RN’s in the out of hospital transport environment is the industry standard and should be used as a model for best practice in the state by the Virginia Board of Nursing.  Flight nurses, critical care ground transport nurses, and neonatal-pediatric teams across the state need to be recognized for the nursing contributions to patient safety and quality they can make outside of healthcare facility walls.      

Any proposed changes should include a carve out for critical care transport nurses,  employed by the agency, with documented training, education, and certification in the prehospital/transport environment to allow them to function as nurses under the agency license and under the supervision of the agency medical director.

Respectfully submitted.