I do not support clinical hours instead of board certification as qualification for registration as a CNS in Virginia.  I ask that the BON deny this request. This is not congruent with the Consensus Model for Advanced Practice Nursing and moves away from a standardization of CNS practice in the United States. The Virginia Association of Clinical Nurse Specialists and the National Association of Clinical Nurse Specialists along with various other groups are working to guide current practice into alignment with the Consensus Statement. Developing licensure requirements for Advanced Nursing Practice are underway and supported on a national level. I am involved with this process in my position as secretary of the Virginia Clinical Nurses Association. We will continue to bring forth the concerns of CNSs and advocate for CNSs to be permitted to practice to their full scope of training and education.