I oppose the proposed fee increases for RN and APRN licensure. Greater than 60% increases in licensure fees are unreasonable. The fee increases could be a barrier for nurses from obtaining licensure and deter nurses from renewing their licenses, contributing to the shortage of nurses practicing in Virginia. I urge the Board to consider a lower, more reasonable increase. 

I oppose the increases because they seem to be too high. Everyone already has inflation that is 300% on many other things. Everyone is now struggling to make ends meet. These increases will hurt the nurses and nurse supportive roles more than help and could prevent graduating nurses from even making application to take their boards.  A much smaller increase would be understandable, but the percentage rates for each of these are way too much, too high. 

I oppose the proposed fee increase for obtaining and renewing nursing licenses in the Commonwealth of Virginia. Here are some notable mentions and comparisons of other states that RNs and APRNs may wish to move to if these proposed changes go into effect. I respectfully request the board consider removing the Board of Medicine from unnecessarily regulating APRN practice to reduce any unnecessary costs rather than having this come from the pockets of APRNs who already pay money to collaborating physicians. 

Virginia initial / renewal RN: $250 / $130 APRN: $250 / $130

• Virginia jointly regulates APRN practice by Board of medicine & board of nursing. There is no independent practice for CNS (APRN) and significant limits of scope of practice for all APRNs. I would never approve a 65% increase in RN renewal, 100% increase in APRN application and 65% increase for renewal unless there was promise that we are able to work at the top of our education and training. This is an unacceptable proposal unless significant changes are made.

Rhode Island RN: $135 / $135 APRN: $145 / $145 https://rules.sos.ri.gov/regulations/part/216-10-05-2

• higher cost of living & independent CNS practice authority

Washington State: RN $138 / $188 APRN: $130 / $130 https://nursing.wa.gov/licensing/nurse-license-fees

• higher cost of living and independent practice authority for CNS / APRN

New York RN: $143 / $73  https://www.op.nysed.gov/registration-renewal/online-registration-renewal

• higher cost of living

Florida RN: $110 / $75 APRN: $110 / $60

• https://floridasnursing.gov/licensing/

I am happy to discuss the importance of supporting our nursing professionals. I hope to keep this valuable human resource in the great Commonwealth of Virginia instead of driving them out due to high licensure fees.

Over a 60% increase in the fees associated with nursing licensure is much too high considering the increased cost of living and inflation. Placing this burden on already burdened professionals who struggle to make ends meet given the low pay for nurses is outrageous. There are a variety of other states that have higher cost of living with less fees for licensure. 

It is important that the Board of Health Professions take into consideration the need for a skilled professional nurse workforce for the near and distant future. We are in an age of potential loss of many skilled Baby Boomer nurses, which would compromise the health of Virginians. This licensing fee increase for both RNs and APRNs is not reasonable. 

Nurses are already underpaid and have to pay for supplies and uniforms out of pocket. Raising the fee only puts more burden on the nurses which may limit how many join or stay in the workforce and nurses are shortstaffed to begin with. 

The Virginia Board of Nursing is proposing astronomical fee increases for all licensed professionals. I read through the proposal and can see that there have been or will be salary increases of around 28% from FY2020 to 6/2025. The fees increases they are proposing are to the tune of 60-100% for most all of my fellow healthcare professionals

While considering the rising cost of living and a great deficit in salary increases in today's world these fee increases are extremely concerning to me and others in my profession. While I understand the mentioned 28% in salary increase and the ever-rising cost of operations; I ask myself if 60 to 100% is justifiable? I can speak on behalf of myself and can without any doubt say that I have not received 60-100% salary increase in the past few years nor do I expect it from a local nonprofit agency. I can also say that insurances both private and public such as Medicare and Medicaid are not reimbursing agencies 60-100% more so there is not any correlation to the fee increases with what is going into healthcare worker's or agency's pockets.

For states that border VA have fees around of $90 for RN, $40 for LPN and $90 for APRN Annually (WV), $100 for both RN/LPN, $50 for APRN Annually (NC) and $100 for LPNs/RNs and $110 for APRNs Annually (TN).

While I know this is currently at the state level, I am asking for your help in bringing awareness to the detrimental effects of these increases and advocating for a healthcare field that is already crumbling. The future of our communities and population will most definitely be negatively impacted by these.

This is ridiculous. $110 increase!?!

I do not support a one-year licensing fee increase as a budgetary remediation proposal for the $2,548,279 budget deficit. The deficit did not manifest in one year and cannot be corrected "on the backs" of licensees in one year.

Additionally, there is a disproportionate "double-dipping" option in the fee increases for Advanced Practice Registered Nurses (APRN) as APRNs hold 2 licenses. I do not support these increases.  APRNs will pay $230/2 years to renew their RN licenses and $130/2 years for their APRN licenses.  The fee increase proposal rationalizes: "The fees for APRNs are increased at a greater rate than practitioners... This is due to the higher earning potential of APRNs and a reflection of slightly lower current fees for this category". 

This calculation omits a formidable barrier to many APRNs who do not practice at a full scope of practice and cannot work in positions with a "higher earning potential." In addition to omitting scope of practice barriers, no rationalization of personal budgets is considered in this proposal either.  There is no data supporting that APRNs' personal budgets could withstand this double indemnity more than any other professions listed in the proposal. 

While expenditures are detailed in the 2024-2025 strategic plan for the VBON and licensure fees account for 92% of the budget, complaints, IT needs, salaries and employee benefits have shown the most significant increase in expenditures for the Board in FY24. VBON predicts this will likely continue. 

The board appears to be trying to minimize the need for additional program staff; however, information technology, expanding online renewals, expanding agency electronic records management, and standardizing processes will need further funding. 

Will drastic fee increases occur in subsequent annual DHP/VBON budget reviews?  I hope not, as many nurses are licensed in multiple states, and our closely bordered sister states look very welcoming. We (Virginia) may lose practicing RNs and APRNs due to the lesser licensing costs in other nearby states. 

I cannot think of a single industry where such a drastic increase in the licensing fee required for the license to work is considered as a plausible option. New graduate nurses are already coming in to the profession with mounting debt, and will have to find a way to pay an even higher initial licensing fee. Renewals are increased, and these fall within the first years of establishing a career. These newest nurses have barely begun to pay their student debt, build a savings account, or start retirement funds. They are living on an hourly wage that is already much lower than the promised base increases and wages of nurses in states around Virginia. 
This deficit is one from a change made 8 years ago. Logically, the expectation should be that a revenue loss would take at least 8 years if not longer to recover. A sustainable increase, continued market analysis of pay rates, and legislation to ensure positive changes in nursing practice should be the primary focus.