Thank you for the opportunity to comment on the proposal to alter the Regulations Governing Nursing Education Programs [18 VAC 90-27]. The valuable conversation surrounding this issue sheds light on the current nursing and nursing faculty shortages. In essence, we can't hope to make progress in developing new nurses without sufficient numbers of qualified nursing faculty. I support the concept of broadening the requirements to align with the American Association of College of Nursing Essentials as mentioned by Shelly Smith, allowing individual schools to "vet the expertise of their own faculty" and help meet the clinical teaching needs of nursing programs. As nursing education moves to embrace a competency-based model designed to improve workforce readiness, it must be acknowledged that competencies are most evident in bedside care delivery. 

We must also acknowledge the trends of new nurses fleeing the bedside, often reporting they are unprepared to face the demands of clinical practice in a chronically understaffed environment. Students need instructors with clinical expertise to guide them through the challenges of advocacy, critical thinking, and in-the-moment care decisions. We need to collaborate with our clinical partners to help retain the new nurses entering practice by ensuring we are truly preparing them for that transition.

As an experienced nurse educator, I fully acknowledge the importance of adult learning theory, test construction, NGN-NCLEX preparation and skills developed within a masters or doctoral program. However, those areas of expertise are largely required in didactic education. Additionally, many in academia begin to focus on research, evidence-based practice, and other academic pursuits that limit time at the bedside. We need both expert educators and expert clinicians to support nursing education. 

Suggestions by Karen Weeks and Jamie Robinson, seem eminently logical. Specifically address the qualifications for clinical faculty teaching at the bedside to include at least 5 years of experience within a specific specialty with preference for those with specialty certification, combined with documented training in nursing education principles and close supervision by master's prepared faculty. I firmly believe there is a solid middle ground in this discussion. One that recognizes the critical nature of clinical experience to support clinical education, partnered with experts in nursing education. Together, we can focus on supporting student ability to learn the science and art that undergirds professional practice, patient safety, licensure and successful transition to practice.