March 27, 2007

I am writing on behalf of the Virginia Council of Nurse Practitioners (VCNP) in support of the proposed action to amend 18 VAC 90-30-80 to clarify the conditions for initial licensure as a nurse practitioner, as well as prohibited practice.

The proposed amendment clarifies that a nurse practitioner, in order to hold a license and practice in Virginia, must also hold an active, current license as a registered Nurse, and that it is not possible for a person to have an inactive RN license and maintain licensure as a nurse practitioner.  Further, the proposed amendment clarifies that if the RN license is suspended or revoked, the nurse practitioner’s license is also restricted or revoked.

VCNP supports the proposed amendments and agrees with the Board of Nursing that the amendments are necessary because inactive licenses are now being proposed for registered nurses who are retired and no longer practicing, but who may want to maintain a Virginia license.

VCNP appreciates the opportunity to submit public comment.  If you have any questions, please do not hesitate to contact me. 

Sincerely,

Carola Bruflat, MSN WHNP

President

Virginia Council of Nurse Practitioners

2209 Dickens Road
Richmond, VA 23230-2005