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.