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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4/7/19  6:56 am
Commenter: Linda Thurby-Hay DNP, RN, ACNS-BC, BC-ADM, CDE

Why regulatory change is needed?

The petition of the Virginia Association of Clinical Nurse Specialists speaks to two specific concerns raised by Clinical Nurse Specialists (CNS): 

1. Denial of registration: The Commonwealth has denied CNS registration to those whose national CNS certifications did not align with the 2008 Consensus Model language, even though their programs were completed years before the Consensus Model was accepted. These decisions did not honor the education and certification options available to these nursing experts at the time they completed their programs. This is particularly true of those who were certified using the Core CNS certification examination, promoted by the National Association of Clinical Nurse Specialists as a viable alternative. Additionally, this petition clearly specifies that all CNS certifications, including those that have been retired, are acceptable. The language is woven throughout this petition align regulations of those who are registering initially, by endorsement, renewal or reinstatement. 

2.  Differentiating CNS from professional nursing practice:  There is national acceptance in the nursing community that four nursing roles are practicing at the advanced practice level, e.g. Certified Nurse Midwives, Certified Registered Nurse Anesthetists, Nurse Practitioners and Clinical Nurse Specialists. The National Association of Clinical Nurse Specialists's Statement on Clinical Nurse Specialist Practice and Education, now in its third edition, clearly articulates CNS's advanced practice nursing competencies. In this petition, we have referenced this document as was advised by Board of Nursing (BON) representatives in our fall meeting with them, to answer the earlier BON call that CNS practice be differentiated from professional nursing practice. Current CNS regulations permit varied interpretation, dependent on the individual board member's understanding of advanced nursing practice and the intent of the Consensus Model. The proposed language would end this discrimination.

In the Commonwealth, the continuing struggle with our respected physician colleagues, to practice nursing independently, has put political agendas ahead of the citizens of Virginia and their health. Clinical Nurse Specialists are the only nursing role that are educationally-prepared and nationally-certified nursing experts in specialty care. Their knowledge and skill should be recognized and honored.