I completely disagree with the petitioners request to the Board to amend 18VAC90-27-60(A)(4) and allow nurses with 20 years or more of experience to serve as faculty for nursing education programs. 

Experience alone does not qualify a nurse to effectively educate nursing students and prepare them for success in passing NCLEX and entering the nursing profession as a novice nurse.  I believe that experience and the additional education (Master's degree in nursing education specifically and/or a DNP in nursing education) in combination with clinical (bedside) nursing experience are needed for a nurse to be an effective nurse educator.  There are so many dynamics to teaching in the didactic classroom setting - understanding adult learning theory, evaluation and assessment strategies, curriculum mapping, test writing, blueprinting and item analysis, providing testing accommodations, understanding NGN/NCSBN questioning, being familiar with higher education organizational dynamics, accreditation requirements, etc.  Bedside/clinical experience does not teach or prepare a nurse for the academic environment.  I strongly vote against this proposed amendment.  This is a big NO for me.  Thank you for the opportunity to share my opinion.

I appreciate the opportunity to provide comments on this Petition for Rulemaking for Statutory Authority: § 54.1-2400 affecting 18 VAC 90 - 27.  Without having context provided, I can only assume that the logic behind the petition is to provide an alternative route into nursing education to alleviate the nursing faculty shortage. It is evident that the nursing faculty shortage is concerning, but I cannot endorse this approach.

Nursing faculty need to have expertise in nursing practice. Years of experience could be an indicator practice but it does not necessarily indicate immersion in or expertise in a particular area. Nursing faculty need to have training or formal education in the principles of teaching in order to be effective educators as well. Teaching is a specialty within itself and it would be presumptuous to assume that without training any nurse inherently has the skills and competence of a teacher. 

We do need to consider new ways to approach nursing education. But, to protect the public, which is the role of the Board of Nursing, more parameters than "20 years of experience" are needed. I would suggest the following amendment to the petition:  allow BSN-prepared nurses who have 5 years of experience in a single area of focus and have documented training in nursing education principles to be eligible to work as clinical faculty with the stipulation that they are supervised by an experienced master's prepared faculty member.

Once again, thank you for the opportunity to provide comments. I look forward to hearing the decision of the Board. 

The University of Virginia appreciates the Board of Nursing’s responsiveness to the nursing workforce crisis and its correlation to the nurse faculty shortage. While twenty years of practice brings with it a wealth of knowledge, we believe the constraint limits other highly qualified nurses to serve in this capacity. The American Association of the Colleges of Nursing’s recent call for comment on revisions to the Essentials includes language in Key Element II-F, “Faculty teaching clinical in the baccalaureate program have a graduate degree or a baccalaureate degree. Those faculty who do not have a graduate degree have significant clinical experience and are enrolled in a graduate program or are otherwise qualified for the area(s) in which they teach. Evidence of such "other" qualification includes significant clinical experience and expertise (e.g., graduate-level courses or continuing education units, national certification) relevant to the clinical area(s) and meaningful engagement with and formal oversight by a graduate-prepared faculty member.” It is our hope that Virginia’s Board of Nursing can follow AACN’s lead in providing schools the flexibility to vet the expertise of their own faculty. At a minimum, our hope is that the suggested twenty years could be reduced by at least half. Thank you for the opportunity to provide public comment. 

As seasoned nurses embark on well-deserved retirements, they carry with them a wealth of invaluable knowledge cultivated over 20 or more years of dedicated practice. Their mastery in the field is a testament to their commitment and experience. In the wake of this significant wave of retirements, there is a unique opportunity for these skilled professionals to transition into clinical teaching roles. With their extensive clinical background, they are perfectly primed to impart practical wisdom to the next generation of healthcare providers. Their wealth of experiences not only enhances the educational landscape but also ensures that the legacy of their expertise continues to positively influence the nursing profession. I chose 20 years as an arbitrary number. I have had the greatest clinical education from seasoned nurses with diplomas. 

First, I would like to thank the ability to have public comments to the petition for the Board amend 18VAC90-27-60(A)(4) to allow nurses with 20 years or more of experience to serve as faculty for nursing education programs. While I certainly appreciate the expertise in years served in the nursing profession and the value to the profession; however, I can not endorse years of experience as requirements to serve as nursing faculty. The nursing shortage is felt by all, including nursing faculty. A myth that needs to be acknowledge is that the transition from practice to academia is an easy transition without any additional education. Quality nursing faculty are advanced nurses with the professional development and expertise in assessing, measuring, and ensuring student outcomes and competence. I would like to see more parameters beyond the years of experience. I would like to see the development of future faculty under experienced faculty to mentoring within the clinical areas. These future faculty should have more than 7 years experience, BSN prepared, preferred national certification endorsement, and professional development/training related to nursing education competencies. 

Thank you again for the opportunity to contribute to this discussion. 

Thank you for the opportunity to comment on the proposal to alter the Regulations Governing Nursing Education Programs [18 VAC 90-27]. The valuable conversation surrounding this issue sheds light on the current nursing and nursing faculty shortages. In essence, we can't hope to make progress in developing new nurses without sufficient numbers of qualified nursing faculty. I support the concept of broadening the requirements to align with the American Association of College of Nursing Essentials as mentioned by Shelly Smith, allowing individual schools to "vet the expertise of their own faculty" and help meet the clinical teaching needs of nursing programs. As nursing education moves to embrace a competency-based model designed to improve workforce readiness, it must be acknowledged that competencies are most evident in bedside care delivery. 

We must also acknowledge the trends of new nurses fleeing the bedside, often reporting they are unprepared to face the demands of clinical practice in a chronically understaffed environment. Students need instructors with clinical expertise to guide them through the challenges of advocacy, critical thinking, and in-the-moment care decisions. We need to collaborate with our clinical partners to help retain the new nurses entering practice by ensuring we are truly preparing them for that transition.

As an experienced nurse educator, I fully acknowledge the importance of adult learning theory, test construction, NGN-NCLEX preparation and skills developed within a masters or doctoral program. However, those areas of expertise are largely required in didactic education. Additionally, many in academia begin to focus on research, evidence-based practice, and other academic pursuits that limit time at the bedside. We need both expert educators and expert clinicians to support nursing education. 

Suggestions by Karen Weeks and Jamie Robinson, seem eminently logical. Specifically address the qualifications for clinical faculty teaching at the bedside to include at least 5 years of experience within a specific specialty with preference for those with specialty certification, combined with documented training in nursing education principles and close supervision by master's prepared faculty. I firmly believe there is a solid middle ground in this discussion. One that recognizes the critical nature of clinical experience to support clinical education, partnered with experts in nursing education. Together, we can focus on supporting student ability to learn the science and art that undergirds professional practice, patient safety, licensure and successful transition to practice.