I add my oppposition to the Hurley petition to substitute additional clinical hours for a certification examination.   I have been credentialed by the Virginia Board of Nursing as a CNS since 1990. I currently serve as  the dean of a nursing education program  in the Commonwealth and practice clinically as a PMHCNS.  I support  the rationale of  those who have previously commented in opposition and offer the following additional rationle for consideration.  Designating  2000 hours of clnical practice  as the measure of ensuring sufficient expertise for initial designation as a  CNS is problematic because practice hours alone are  not  reliable valid objective measures to ensure initial competence and expertise.   The petition also does not address the issue of  how continued competence over time would be measured and verified in the absence of national specialty certification.