The American Board of Nursing Specialties (ABNS) and the Accreditation Board for Specialty Nursing Certification (ABSNC) appreciate the opportunity to provide comments regarding the VA Board of Nursing Proposal on continuing competence requirements for renewal of an active license as defined in 18VAC90-20-221. On behalf of our ABNS member organizations and those organizations accredited by ABSNC, we fully support the VA Board of Nursing proposal to accept nursing certification for re-licensure purposes as a means of demonstrating continuing competence and life-long learning of registered nurses and advanced practice registered nurses. Nursing certification has long been recognized as a means of “protecting the public.” Accepting nursing certification programs that have been accredited is a means for the Board of Nursing to be assured that such programs are developed and based on rigorous quality standards in the credentialing industry. The Accreditation Board for Specialty Nursing Certification (ABSNC), which focuses specifically on accrediting nursing certification programs, is one of two organizations that grant accreditation to such programs that demonstrate compliance with its standards. The other national organization is the National Commission for Certifying Agencies.

We would like to bring your attention to section 18VAC20-90-10 which defines “accreditation by the National League for Nursing Accrediting Commission (NLNAC) or by the Commission on Collegiate Nursing Education (CCNE).” This definition limits the definition of accreditation to the accreditation of academic educational programs and does not allow for accreditation by the two accrediting bodies for national nursing certification programs.

Thank you for recognizing that re-licensure and specialty nursing certification allow a registered nurse and advanced practice registered nurse to demonstrate continuing competence directed at providing safe care to the public.

Sincerely,

Bonnie Niebuhr, MS, RN, CAE

Chief Executive Officer

ABNS and ABSNC