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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3/29/19  9:12 pm
Commenter: Pamela Sharp, PhD, RN, CNS-BC, ODU & Bon Secours MIH

Support change in the regulations regarding CNS registration and practice in Virginia

It was recognized in 1995 that there were many inconsistencies with how CNSs were viewed, trained, and employed across states, thus the NACNS was formed.  NACNS joined with other groups, including NCSBN and specialty nursing groups to identify the spheres of influence and develop Core CNS Competencies -- agreed upon and formalized in 1998, with the first minor revision published in 2004. The document is reviewed every 5 years.

Key elements of 1998 document included licensed RN with graduate preparation from a CNS program, clinical experts in diagnosis and treatment of illness and delivery of evidence based nursing interventions, and advanced knowledge with a specialty focus.  Specialty areas are always evolving as the science of care evolves. A clinical nurse specialists’ specialty may typically be defined by population, setting, disease or medical subspecialty, type of care, or type of problem.  Regardless of specialty or setting, CNSs enact the same core competencies. 

Even with the 1998-2004 Core Competencies outlining the CNS role, states were still not all consistently recognizing the CNS as an APN.  The next step in attempting to better align the role of the CNS and plan for the future was to develop the APRN Regulatory Model or consensus document.  This was completed in July 2008, revised in 2010, with full implementation expected by 2015.  Full implementation still has not occurred in all states in 2019.  In fact, groups who worked on the model have stated that “the more states that pass this model in piecemeal manner may result in problematic variations between states” and loss of consistency, which was the point of the model.

CNS testing was also evaluated in 2008.  This is when the population specific tests were devised to match the new model, although not all fully implemented until 2010.  A Grandfathering Clause or a similar statement of exceptions was recommended for all states so that APNs who were educated and practiced at the graduate level prior to consensus model were able to register as a CNS “regardless of current recognition status” and did not have to meet new requirements. An example is the old med-surg/adult health exam which was updated to the CORE exam, keeping an option for those who had already completed their CNS training and allowing time for programs to admit students under the new model and finish the “teach out” of old curriculums. 

Virginia has not fully recognized or implemented the APRN Regulatory model, including maintaining a fair grandfathering clause resulting in CNSs who currently hold national certification, without lapse, and years of experience at the graduate level being unable to register in the state.  The dates nurses attended their CNS program and competencies under which they trained, which should match their testing, are not consistently being recognized.

The proposed change in CNS registration and practice in Virginia will address the importance of not excluding CNSs solely based on an exam, especially when competence can be supported through work experience, portfolio, recommendations, etc.  It would eliminate hardship being placed on CNSs in the state and would also possibly increase the number of CNSs registered in the state, as there are likely some who are not attempting to register and practice to their full potential given the current barriers.  This could also help fill the gap in advanced practice providers, which are in great demand. 

CommentID: 70782