The Board should consider how to measure nursing competency.  What does the Board mean by nursing competency?  After defining what what you mean by nursing competency, then the Board should consider what specific things will be observed after the regulations are instituted that is not currently being observed through the existing regulatory program.  Enforcing continuing education or allowing publication of nursing work in a professional journal to demonstrate competence is not necessarily a good determinant in whether a particular nurse is competent.  Requiring periodic testing to maintain a nursing license, which I believe is done with doctor licenses, may have the greatest impact on protecting competence but comes with the greatest amount of cost. 

The Board should characterize the state of nursing competence.   What is the rate of enforcement action against nurses for lack of competence?  What are the risk factors that have been historically observed in nurses being penalized for lack of competence?  Will these new competency regulations reduce the risk factors?  Will the new regulations actually reduce the rate of enforcement action against bad practice? 

I notice that the NOIRA only talks about competency assessment and evidence of competency with respect to renewing licenses; however, I believe the regulations should actually make a difference.  Asking for additional evidence does not necessarily improve competency in the field and could become just a paperwork or last minute course that nurses rush through to renew a license.    Inserting a few new evidence requirements will not be of any value if it actually does nothing to increase the competency as demonstrated through measured results.  What metric is best used to measure whether a nurse is competent?  Again, what would you expect to happen, what will reduce or increase, if the regulations were to actually improve competency?