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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4/12/19  9:39 am
Commenter: Sarah Cullen, DNP, ACNS-BC, RN

Support the CNS petition

I support the the Virginia Association of Clinical Nurse Specialists’ petition to revise the regulations governing Clinical Nurse Specialist (CNS) registration and practice.  CNS practice standards are clearly outlined by the National Association of Clinical Nurse Specialists (NACNS). All CNSs should practice according to national standards. CNSs have advanced education and certification as a CNS, and are recognized as billing providers by CMS. However, CNSs in Virginia are not able to practice to these national standards, due to state level restrictions of lack of full practice authority and the lack of licensure. This hinders our ability to practice to our full extent of our education and training. We need to be recognized and treated as advance practice registered nurses (APRNs) – NOT as “professional nurses” as current regulations suggest. We are trained and certified, as APRNs. Similar to nurse practitioners, yet we are treated completely different. As the nation struggles to improve access to care (and specialized care) it is incumbent on the Commonwealth of Virginia State board of nursing to follow those recommendations in line with 17 other states and territories of the US and remove the practice barriers within this state. The revisions align with nurse practice acts and regulations in neighboring states, across the nation, as well as the tenets of the Consensus Model for APRN Regulation (2008) and the National CNS practice standards. I urge the BON to continue to support the nurses within the state (all nurses) and approve the proposed changes.