I have recently retired and feel that this new regulation would cause a hardship for those like me who are now on a fixed income.  It will be hard just to pay my license fees. I may not work, but I am not ready to give up my R.N. status.  I would appreciate your consideration on this matter. 

Martha S. Hodges/RN/Adm.

I appreciate the Board accepting the suggestion of course development as a continued competence activity.  However, Section 18VAC90-20-222 does not appear to provide any requirements for documentation of this activity unless the wording in 18VAC90-20-222 (B8) is broad enough to cover this.  If not, then 18VAC90-20-222 should, in my opinion, include documenting compliance for developing a course.

Since both teaching and developing courses are mentioned in the same Sections {18VAC90-20-221 (A6) and (A7)}, perhaps documenting compliance of both could be in the same Sections {18VAC90-20-222 (B6) and (B7)}.  I would suggest the following wording, as an example, to Sections 18VAC90-20-222 (B6) and (B7) with changes in bold italics enclosed in brackets:

6. Evidence of teaching [or developing] a course for college credit shall include documentation of the course offering, indicating instructor [or developer], course title, course syllabus, and the number of credit hours. Teaching [or developing] a particular course may only be used once to satisfy the continued competency requirement unless the course offering and syllabus has changed.

7. Evidence of teaching [or developing] a course for continuing education credit shall include a written attestation from the director of the program or authorizing entity including the date or dates of the course or courses and the number of contact hours awarded. If the total number of contact hours totals less than 30, the licensee shall obtain additional hours in continuing learning activities or courses.

My wording may not be optimal, and, again, is presented as an example only.  However, I do believe that some wording for documenting course development should be included in 18VAC90-20-222.

Thank you for the opportunity to present my views on this matter.