I am in full support of the Virginia Association of Clinical Nurse Specialists petition to revise the regulations governing Clinical Nurse Specialist (CNS) registration and practice. This revision is a key step toward overcoming barriers and challenges to CNS practice that persist in Virginia. Restricted practice in Virginia for CNSs limits access to care for citizens who will benefit from the expert advanced nursing care provided by CNSs.  CNS practice standards are clearly outlined by the National Association of Clinical Nurse Specialists (NACNS). Any Commonwealth of Virginia regulatory, registration or licensure changes and CNS board certification requirements should be based on the national standards set forth in the Consensus Statement and by the NACNS.  Consistent with the practice standards seen in most states, the Clinical Nurse Specialist should be enabled to improve the health of the communities they serve in the Commonwealth of Virginia by permitting practice at their full scope of education and training.

Respectfully,

Ellen M. Harvey