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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3/18/19  9:00 pm
Commenter: Linda Thurby-Hay

Support changing the regulations related to CNS practice

In 2008, the National Council of State Boards of Nursing (NCSBN) published the Consensus Model for APRN Regulation to standardize regulatory language for all four APRN roles, and offered a Model Practice Act to guide language changes. Those with vested interests in subjugating advanced nursing roles continue to challenge the ability of APRN roles to practice without oversight across the nation and here in Virginia. As we have seen year after year in Virginia, all four APRN roles struggle to align the Code of Virginia with the Consensus Model. In Virginia, Clinical Nurse Specialists (CNS), in particular, experience significant barriers to fulfilling their obligation to the public of delivering specialty nursing care for the populations served. This petition is the next step in moving CNS practice forward in Virginia. 

Today, I am writing in full support of this petition of the Virginia Association of Clinical Nurse Specialists. Barriers to CNS practice need to be removed, one by one, if necessary! Although CNSs enjoy title protection and are identified as Advanced Practice Registered Nurses (APRN) in the Code of Virginia, the interpretation of current regulations suggest that CNS practice is no different than professional nursing practice. The designers of the Consensus Model would disagree, as do CNSs everywhere. APRN practice (including CNS practice) builds on the knowledge and skill of RN practice; the difference lies in the depth and breadth of understanding of nursing phenomena seen in specialty nursing practice, not in whether we can prescribe (although we are educationally-prepared to do so). CNSs conduct advanced assessments, develop plans of care and intervene with advanced therapies, which is consistent with the medical model of physician specialist practice building on the education of the primary care physician.  

It is time to remove barriers to CNS practice in Virginia. This petition is the next step for this knowledgeable and skilled advanced practice nursing role.