I appreciate that this regulation is being clarified.  I am concerned about the change of “licensed practitioner” to “physician” in the regulation to sign the DDNR form with the patient or their authorized representative.  I see that “physician” is defined as, "Physician" means a person licensed to practice medicine in the Commonwealth of Virginia or in the jurisdiction where the treatment is to be rendered or withheld.  I am concerned that this will lead to confusion about Nurse Practitioners or Physician Assistants signing these forms.  I think that leaving the licensed practitioner is clearer then changing to physician. 

This is the area of concern:  Durable DNR orders Order Forms, including POST or POLST forms, shall be completed filled out and signed by a licensed practitioner physician and signed by the patient or patient's authorized representative.

I appreciate your consideration.