Agencies | Governor
Virginia Regulatory Town Hall
Department of Health Professions
Board of Nursing
Regulations Governing the Practice of Nursing [18 VAC 90 ‑ 19]
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4/16/19  9:05 pm
Commenter: Rickie T Simpson PHD APRN-CNS,BCPCC, C-IAYT

Supporting the change in the CNS scope of practice


I fully support the Virginia Association of Clinical Nurse Specialists’ petition to revise regulations related to the registration and practice authority for Clinical Nurse Specialists (CNS) in the Commonwealth . The proposed revisions will decrease and/or eliminate artificial barriers to the scope of practice for the CNS. It is confusing and artificial to restrict my practice when my training is comparable to that of an NP.  The Consensus Model for Advanced Practice Registered Nurses (APRN) (2008) was published by the National Council of State Boards of Nursing (NCSBN) to provide nationally recognized standards of practice and licensure for APRNs in all states.  Y Virginia has not fully adopted the Consensus Model related to the CNS, thereby creating barriers to scope of practice and essentially making three levels of nursing practice in the Commonwealth-RN,CNS and NP.   These barriers to scope of practice are depriving citizens of the Commonwealth with access to comprehensive medical care and services especially in my area of expertise— psychiatric care. This is particularly true in rural areas of the Commonwealth that have limited mental healthcare providers and soaring mental health wait lists.  Additionally, the prevalence of individuals suffering from chronic mental health disorders in Virginia makes this petition for CNS full practice authority (i.e., prescriptive authority) urgent.      

CNSs have the education and training, as well as national certification, to practice and be recognized as an APRN in many other states.  The uniqueness of the role’s influence and expertise in clinical care make the CNS a valuable asset to healthcare in Virginia.  I urge your strong support of this petition which will provide a cost-effective and ready resource to the citizens of Virginia who can least speak for themselves. 

CommentID: 71519