The University of Virginia appreciates the Board of Nursing’s responsiveness to the nursing workforce crisis and its correlation to the nurse faculty shortage. While twenty years of practice brings with it a wealth of knowledge, we believe the constraint limits other highly qualified nurses to serve in this capacity. The American Association of the Colleges of Nursing’s recent call for comment on revisions to the Essentials includes language in Key Element II-F, “Faculty teaching clinical in the baccalaureate program have a graduate degree or a baccalaureate degree. Those faculty who do not have a graduate degree have significant clinical experience and are enrolled in a graduate program or are otherwise qualified for the area(s) in which they teach. Evidence of such "other" qualification includes significant clinical experience and expertise (e.g., graduate-level courses or continuing education units, national certification) relevant to the clinical area(s) and meaningful engagement with and formal oversight by a graduate-prepared faculty member.” It is our hope that Virginia’s Board of Nursing can follow AACN’s lead in providing schools the flexibility to vet the expertise of their own faculty. At a minimum, our hope is that the suggested twenty years could be reduced by at least half. Thank you for the opportunity to provide public comment.