How will you hold those who are in the nursing compact accountable, if the other states do not require CE to renew?

The Board should consider how to measure nursing competency.  What does the Board mean by nursing competency?  After defining what what you mean by nursing competency, then the Board should consider what specific things will be observed after the regulations are instituted that is not currently being observed through the existing regulatory program.  Enforcing continuing education or allowing publication of nursing work in a professional journal to demonstrate competence is not necessarily a good determinant in whether a particular nurse is competent.  Requiring periodic testing to maintain a nursing license, which I believe is done with doctor licenses, may have the greatest impact on protecting competence but comes with the greatest amount of cost. 

The Board should characterize the state of nursing competence.   What is the rate of enforcement action against nurses for lack of competence?  What are the risk factors that have been historically observed in nurses being penalized for lack of competence?  Will these new competency regulations reduce the risk factors?  Will the new regulations actually reduce the rate of enforcement action against bad practice? 

I notice that the NOIRA only talks about competency assessment and evidence of competency with respect to renewing licenses; however, I believe the regulations should actually make a difference.  Asking for additional evidence does not necessarily improve competency in the field and could become just a paperwork or last minute course that nurses rush through to renew a license.    Inserting a few new evidence requirements will not be of any value if it actually does nothing to increase the competency as demonstrated through measured results.  What metric is best used to measure whether a nurse is competent?  Again, what would you expect to happen, what will reduce or increase, if the regulations were to actually improve competency?

I believe that nurses must remain competent. However, our forms of practice are so diverse, it is important that competency be equally diverse. As a nursing educator/administrator, my concern is that any established competency include practice expectations within the educational administrative role of practice.  As a professional I am totally aware that if I  moved to another setting, I would need to sharpen my skils in that area of nursing practice.  In other words, competenies should be very broadly defined to reflect the diversity in nursing.

It is not clear to me how the Board of Nursing, whose purpose is to assure safety in nursing practice, can effectively design competency requirements to reflect the diversity in nursing practice. Does research sponsored by the NCSBN support the added cost to the Board of Nursing, and to nurses, for this additional regulation? In the states where continuing competency is required, are the citizens safer becuase of this additional regulation?  Do these state boards have fewer incidences of malpractice or untoward incidents? 

I worked in a state that required ongoing competency.  A number of nurses who attended the workshop, sat in the back row, and read the newspaper throughout the entire workshop.  When I think of ongoing competency, this is the picture I see.

Because the role of the registered nurse is dynamic and flexible, it is important for all registered nurses to continue competency in workplace skills. It is our understanding that other states have enacted continuing competency regulations with success. For the safety of the citizens of the Commonwealth of Virginia, all nurses who care for them must be able to demonstrate current and continuing competency. The Virginia Board of Nursing, having studied other states’ regulations and discussed the issue with other NCSBN members, has developed a variety of standards that can be adapted to most nursing venues. Bryant & Stratton College Nursing Program, having examined the proposed regulatory action, commends the Virginia Board of Nursing on finding safe, flexible, and reasonable solutions to the issue of demonstrating continuing competency.

I am writing as a nurse educator to request the nursing education (teaching classes and clinical) be counted as practice hours. I also request that the continuing education hours required as a educator also count toward the total hours required for this area for RNs As a nurse practitioner practicing in VA, I request that the continuing education and practice hours required to maintain certification automatically fulfil the requirements for RNs and not require a separate submission/fee. Thank you.

Currently to continue your licensure in VA all you have to do is fill in a few answers then submit a check or credit card #.  Yes, you are asked if you are working and if so, full time or part time, but there is no way to insure this is accurate.  As we strive for quality healthcare, we, as registered nurses, have a duty to continue our eduction and familiarize ourselves with evidence-based guidelines to continually improve our performance.  Merely reporting to work every day,  checking the boxes for renewal and sending in a payment just isn't enough.  I applaud the Board of Nursing for taking this step and look forward to the outcome of this process.

Having intially been licensed in a state that requires continuing education as part of licensure renewal and evidence of continued competency, I applaud the board for looking at this matter.  I have been practicing practical nursing in the metro DC area since 1981 and have been amazed that none of the three jurisdictions required continuing education.  I do believe the board needs to take caution with several areas:

• Continuing education is costly, and when mandated it often becomes more costly.  Given that you are about to raise licensure fees again, the board must excersise restraint in the fiscal demands in puts on those licensed in Virginia;
• As noted by other writers, continuing education, publications and other proposed areas of proof of competency, do not necessarily provide same; and
• What is the fiscal cost to the Board, will this new regulation cause fees to be even higher?

Thank you for the opportunity to comment.