See attached letter on behalf of the AMTA

The Federation of State Massage Therapy Boards (FSMTB®) is a not-for-profit corporation with membership comprised of massage therapy regulatory boards and agencies in the United States and its territories. The mission of FSMTB is to support its member boards in their work to ensure that the practice of massage therapy is provided to the public safely and competently. FSMTB is writing to clarify some of the education hour requirement language contained in the bill. A misunderstanding around the bill incorrectly implies that a state must require 625 hours of massage education to be eligible to participate in IMpact. The 625 hour requirement applies only to the individual therapist seeking the multistate license, NOT the member state. The provision specifically incorporates “substantial equivalent” language to accommodate future rulemaking to allow for the hours to be met by initial education, continuing education, or a combination thereof. This section does not change the statutory minimum hours of education required for licensure in a state, nor is it a requirement for a state to be eligible to join the compact. The IMpact model legislation is intended to be flexible, long-lasting, and adaptable as the massage therapy profession evolves. The threshold of 625 hours comes from a research project conducted by the Coalition of National Massage Therapy Organizations*. One of the goals of this Entry Level Analysis Project was to identify the minimum number of hours of initial education that massage schools should teach to prepare graduates for the safe and competent practice of massage therapy. In addition, in 2021, FSMTB surveyed roughly 1,000 massage schools. The results revealed the mean number of hours of education that massage therapy students were receiving was 723. This is well above the 625-hour minimum set forth in IMpact. Thus, the 625-hour requirement is an empirically-based standard that both current and future massage therapists should be able to satisfy to obtain the privilege of a multistate license. Thank you for the opportunity to assist you with making fully informed decisions. Should you have any questions about IMpact or the information above, please contact me at ahernandez@fsmtb.org or (913) 681-0380.

Dear Chair Price and Members of the House Health and Human Services – Health Professions Subcommittee: The Federation of State Massage Therapy Boards (FSMTB®) is a not-for-profit corporation with membership comprised of the massage therapy regulatory boards and agencies in the United States and its territories. The Virginia Board of Nursing is a member of the FSMTB. The mission of FSMTB is to support its member boards in their work to ensure that the practice of massage therapy is provided to the public safely and competently. FSMTB supports the adoption of the Interstate Massage Compact (IMpact). IMpact is supported by FSMTB, the Council of State Governments, and the U.S. Department of Defense (DOD). The compact has been thoughtfully developed by a working coalition of subject matter experts representing massage therapy professionals, educators, employers, professional associations, consumers, attorneys, regulators, and legislators. The IMpact language also took into consideration feedback from a three-month public comment period. IMpact supports the relocation of military families by establishing a formal relationship between the states, easing the burdens of relocation both financially and professionally. The DOD believes interstate compacts are the best solution for recruiting and retaining our military forces. IMpact benefits massage therapists by expanding employment opportunities and facilitating professional mobility for licensed massage therapists. This specifically is advantageous for massage therapists engaged in seasonal work in the hospitality and spa industries. IMpact promotes workforce development by reducing regulatory burdens. Impact will increase consumer access to quality healthcare. IMpact protects consumers by permitting only qualified practitioners who complete education, pass the legally defensible and psychometrically valid national licensing exam, and have no disqualifying criminal history, to obtain the multistate license. This improves workforce mobility and the ability of states to protect the health, safety, and welfare of the public. IMpact benefits massage regulatory authorities through its centralized data system to facilitate sharing of licensure and disciplinary data between the states. This information sharing may also mitigate human trafficking and illicit massage by facilitating and improving collaboration between regulatory authorities and law enforcement, to better identify trafficking networks. Finally, IMpact preserves state sovereignty as it retains a state’s jurisdiction over individuals practicing in their state. Thank you for the opportunity to assist you with making informed decisions. Should you have any questions about IMpact or the information above, please contact Ashley Hernandez, Government Relations Specialist, at ahernandez@fsmtb.org or (913) 681-0380. Sincerely, Debra Persinger, PhD, CAE FSMTB Executive Director

Comments Document

I have attached a file with a "no position" testimony for HB 324 from The Council of State Governments.

LeadingAge Virginia supports House Bill 511.

We support HB511. Workforce shortages and the limited availability of health care practitioners specializing in geriatric care have created unnecessary burdens on assisted living communities. Sometimes the shortages are exacerbated by delays in paperwork with licensing agencies. HB511 will help to alleviate the burden caused by delays by allowing the health care practitioner to temporarily practice while awaiting the paperwork processing, etc.

I write this letter with wholehearted support for House Bills 971, 983, and 978. These bills recognize the importance of empowering advanced practice nurses (APRNs) to self-manage as a profession, and move beyond outdated and unnecessary oversight by physicians. They represent a significant step towards acknowledging the expertise and capabilities of APRNs. HB 971, 983, and 978 will allow APRNs to be competitive with our peers in the District of Columbia and Maryland, localities which have far fewer restrictions on advanced practice nursing, and to whom we regularly lose entrepreneurial nurse practitioners who would rather open their businesses out of state than pay a physician a monthly cut of their business in an arbitrary "collaboration." Thank you for your attention to this matter.

Writing in SUPPORT of HB971. Dear Delegates, I write to you a second time today as a Certified Nurse-Midwife and Family Nurse Practitioner in Virginia, and also as a fledgling small business owner. Having been in clinical practice for 6 years in Virginia, across various practice settings, I am permitted to practice independently as a CNM in VA but cannot practice independently with my FNP credential. This is because three of the years I spent working for a CNM-owned private practice do not “count” toward the arbitrary 5-year practice agreement requirement in Virginia. Changing the practice agreement requirement period from 5 to 2 years, and changing the language to enable practice agreements with not only physicians but also with autonomous APRNs would make Virginia significantly less restrictive. It would make me eligible to apply for autonomous FNP license and start providing the full range of care that I am otherwise qualified to provide. Please do not be swayed by physician special interest groups who may use anecdotes in place of reliable research data, or fictional phenomena like “scope creep” to attempt to influence policy to maintain market control. The scope of practice for advanced practice nurses is defined by our professional organizations and in alignment with our education and national certification exams and continuing education requirements. We simply request the professional courtesy to be allowed to practice our professions independently with accountability to our own licenses and to be entrusted with regulating our own profession in the Commonwealth. To keep physicians as gatekeepers to APRN entry to practice hurts small businesses like mine and limits access to high quality, affordable health care that people like me are willing to provide. Thank you, Tana McCoull, CNM, FNP

I'm a nurse practitioner providing care as a solo provider in rural Bedford County and beyond. I'm planning on recruiting a local nurse practitioner who is interested in providing care to our community. After several months of searching, we have been unsuccessful in obtaining a collaborating physician for her at this time. She will have reached her 5 years of practice in April but is short 2,000 hours in qualifying for her autonomous license. By passing this bill, she would be able to join our practice in July if no collaborator is found before that date. It would also allow us to expand services to to the people in our community,. We primarily serve Medicare and Medicaid patients, many of whom have come recently after losing their previous provider due to retirements, relocations and closures. Her additional certification would allow us to expand services to include the care of children as my license is specific to adult patient care. We would also be able to open our Big Island location on more days of the week to accommodate the increase in new patients. Please consider the implications of continuing to limit access to care by this example and allow autonomous practice after 2 years of experience and collaboration. I thank you in advance for your vote for passage of this bill. Sincerely, Phyllis C Everett, NP-C Executive Director, Sapient Health Services, PLLC Past President, VCNP

Comments Document

I need to ask you to support Nurse Practitioners in Virginia to be able to practice at the top of their education, certification, and licensure. Virginia is the most restrictive state in regulating nurse practitioners. Currently a NP must be practicing under a physician collaboration agreement for 5 years. We are requesting full practice authority (FPA) after 2 years of practice. The word “collaboration” does not define the relationship between a NP and physician. The relationships are collegial with mutual contributions from both skilled and knowledgeable professions to improve patient care. That has been my experience as a NP of more than 30 years in practice. However, those opposing this progression feel threatened by the removal of the term “collaboration” and a practice agreement. It is a power struggle that is divisive and impacts patient care- the reason we do what we do-to help patients. Their oversight costs NPs and organization’s money. Data shows that NPs are safe and effective health care providers. Collaboration does not cease when a NP receives his/her FPA. Collaboration in health care is common and a known process that we all practice that should not require regulation or mandated statues. Physicians of various disciplines just like NPs know how to “stay in their lane”. A family practice doctor will collaborate with a cardiologist to determine what is the next test or medication to try for a complex patient. NPs do the same. NPs should not have to be regulated to collaborate. It is a standard of practice. Two bipartisan bills HB 971 and HB 983 will reduce the number of years from five to two, which would align Va with most other states with full practice authority (there are states with zero requirement). NPs have an average of 10 years’ experience as a RN before getting their master’s or doctoral degree and the 2 years under the mentorship of an experienced clinician before granting of full practice authority prepares them for the transition. Currently if the physician retires or leaves the office, the NP must scramble to get another practice agreement signed or risk closing the doors. Access to their provider will cease and leave patients, families, and communities without health care. Across the Commonwealth, thousands of patients entrust their care, and their families care to NPs. The FQHC that I work for operates with NPs that practice exceptional standards in delivering care to a rural and vulnerable population. We are committed to sustaining a collaborative and collegial relationship with our physicians. With much gratitude, Dr. Rosie Taylor-Lewis, Doctor of Nursing Practice, ANP-BC, GNP, PMHNP-BC

I have been a registered nurse since 1987 and an adult nurse practitioner since 2000. I spent 6 years as a member of the GA trying to explain why NPs can provide care independently based on data and other factual information. I found that people believe facts are in the eye of the beholder. It's frustrating. For seventeen years in a row, nurses have ranked number one in honesty and integrity, making them per the national Gallup poll, the most trusted profession in America. And yet, when it comes to the issue of honestly assessing our preparedness for our work, we are told we are liars and not to be trusted because we are ill-prepared and unsafe. People have spent the last several years through and post the pandemic calling nurses heroes, and yet when these same individuals seek professional growth and pursue additional education to practice within a very limited scope, they supposedly do not have the good sense or ethics to stay within their boundaries. Suddenly members of the most trusted profession will go rogue and with utter abandon disregard their professionalism to work outside of their area of competence. It is an insulting and ridiculous argument that wins year after year. As a clinician, educator, and former lawmaker I have struggled to reach a conclusion that isn’t cynical. The conclusion I have reached is that it is institutionalized misogyny. Nursing has been primarily a woman’s profession. For decades nurses were mocked as battle axes, bimbos, handmaidens, and subservients despite being independently licensed professionals and the backbone of the healthcare system. Nurses have always been hardworking, smart, educated, driven, and competent. Advanced practice nurses, like NPs are exactly this with the education to offer additional service to their community. Yet without autonomous practice, NPs are relegated to practicing in an area where they can find a supervising physician. This is not always easy, and frankly, sometimes the only physician available isn’t someone the NP wants due to professional concerns. Others are charged outrageous fees for this mandatory supervision when there is little to no oversight at all. Still, others who have supervision are kept from growing, relegated to unwanted tasks, and undervalued for the privilege. Physicians and institutions have historically made money from NPs kept in submissive roles. Changing this dynamic is not only a hit to the wallet but a hit to the ego. The old model of healthcare is steeped in patriarchy, but there are many professions outside of the traditional physician model who have been trained and educated to support the healthcare needs of patients and communities. We must allow all professions to practice to the fullest extent of their education and training and believe them when they and their credentials say they are able. The quote that comes to mind here is that of the great Justice Ruth Bader Ginsburg, "I ask no favor for my sex. All I ask of our brethren is that they take their feet off our necks." Thank you for your consideration.

Please support the bill to bring the regulatory board structure for midwives in line with other regulated professionals. There is no evidence to support a dual-board structure. Thank you for supporting this bill.

I write this letter with wholehearted support for House Bills 971, 983, and 978. These bills recognize the importance of empowering advanced practice nurses (APRNs) to self-manage as a profession, and move beyond outdated and unnecessary oversight by physicians. They represent a significant step towards acknowledging the expertise and capabilities of APRNs. HB 971, 983, and 978 will allow APRNs to be competitive with our peers in the District of Columbia and Maryland, localities which have far fewer restrictions on advanced practice nursing, and to whom we regularly lose entrepreneurial nurse practitioners who would rather open their businesses out of state than pay a physician a monthly cut of their business in an arbitrary "collaboration." Thank you for your attention to this matter.

In the interest of patient safety and access to care, Virginians deserve confidence in a well functioning regulatory process that isn’t weighed down by unnecessary red tape. Moving license issuance, regulatory enactment and disciplinary review of Advanced Practice Registered Nurses (APRNs) and Licensed Certified Midwives (LCMs) to the Board of Nursing and establishing an advisory committee of Advanced Practice Midwives to the Board of Nursing reduces regulatory burden, serves to increase access to healthcare by decreasing duplicative steps that exist in the current regulatory process and further ensure the public that any disciplinary investigations will occur swiftly. Virginia is an extreme outlier in the country to utilize a joint boards of nursing and medicine structure to regulate all Advanced Practice Nurses and Licensed Certified Midwives. Certified Midwives and APRNs are capable and qualified to solely regulate their professions. To continue to adhere to the rigid view point of the need for regulatory oversight from physicians is outdated. Boards of Medicine lack the requisite nursing and midwifery experience to regulate APRNs or Advanced Practice Midwives. 3 studies submitted by the Department of Health Professions since 2021 support this change. The only statutory laws governing APRNs or LCMs in the Medical Practice Act is definition of these professions. As clarified in the Dec. 2023 report submitted by the Department of Health Professions, approval of regulations governing APRNs and LCMs must go through a cumbersome multi-step process. In practice, regulations are first drafted with a workgroup voted on and recommended by the Committee of the Joint Boards at their discretion and then must be approved by the both the Board of Medicine and the Board of Nursing necessitating separate, multiple board meetings either by following recommendation or by action of the boards without recommendation. Any revision at the individual board level necessitates bringing the language back through the other two boards in order to move on to the next stage of the regulatory implementation process. In review of other health profession boards in Virginia, they are uniformly composed by the professions they represent. The board of psychiatry is made up of psychiatrists. The board of pharmacology is made up of pharmacologists. The board of Optometry is made up of, you guessed it: Optometrists. While you could argue that their roles share overlapping areas of practice with physicians, they do not have medical doctors on their regulatory boards. One must question what is so different about the profession of Advanced Practice Midwifery or Advanced Practice Nursing, that to date Virginia has not recognized these professions as being able to self carry out the duties of regulatory process. Even the the Federal Trade Commission weighed in on this in 2016 when it referred to medical doctors regulating APRNs as anticompetitive, writing: “[w]e urge you to consider whether to allow independent regulatory boards dominated by medical doctors and doctors of osteopathy to regulate APRN prescribing,given the risk of bias due to professional and financial self-interest.” Passing SB351 is a necessary initiative to show all Virginians that reducing unnecessary overregulation and spending while maintaining the integrity of the regulatory process is a goal of our government which is important for sustaining the trust of the public.

Dear Delegates, I’m Tana McCoull, a Certified Nurse-Midwife and Family Nurse Practitioner writing on why HB978 matters and asking you to support it. If the primary function of health regulatory boards should be to protect consumer safety and interests by the least restrictive means necessary, then these two rules of thumb should apply: 1. Any regulatory restriction should have a demonstrated benefit and 2. If multiple options exist to confer the same public protection, the least restrictive option should be chosen. The current structure for regulating advanced practice nursing and advanced practice midwifery requiring the Joint Boards of Medicine and Nursing does not follow these rules of thumb. HB978 would improve upon the existing structure by eliminating a redundancy (Joint Boards structure) which confers no benefit to the public but does significantly, and disproportionately, restrict the ability of APRNs and APMs to regulate their own professions. 1. No benefit to joint board structure: There is no evidence that the existence of a redundant regulatory structure in the form of the Joint Boards of Medicine and Nursing offers any benefit to public safety or other interest. The joint board structure has been touted by physician interest groups as a means for physicians to help nurses regulate the subset of advanced practice nurses and midwives. Proponents of this idea have not been able to produce evidence that our Board of Nursing needs this kind to make appropriate regulatory decisions. Meanwhile, decades of national healthcare quality and safety data show that advanced practice nurses and advanced practice midwives are capable of regulating themselves. APRNs and APMs function safely and to high patient satisfaction when practicing according to their own professional standards, regardless of physician oversight. 2. Less restrictive means exists: The structure of the joint boards is, by its very existence, the most restrictive way to regulate any group of healthcare professionals in Virginia. We know that less restrictive regulation is possible in Virginia, since among our 13 health regulatory boards, comprising 62 professions and over 500,000 healthcare practitioners, APRNs and APMs are the only ones singled out to be regulated by a superimposed redundant board structure. Any revisions APRNs or APMs wish to make to the regulation of their professions must pass through not one, but effectively three regulatory boards, as such changes must first be approved by both the Board of Medicine and the Board of Nursing, then approved again by the Joint Board of Medicine and Nursing, then approved by the executive branch, often with public comment periods in between. This may not seem important, but consider that legislation to allow Certified Midwives to practice passed in 2021, and there is still no application for them to become licensed to work in VA, due to the lengthy regulatory process. Furthermore, HB978 improves upon the existing structure by establishing an advisory board on advanced practice midwifery allowing the APMs a necessary degree of self-representation. This is consistent with the structure for massage therapists who are regulated by the Board of Nursing. So please help pass HB978 to improve upon the existing structure and make the regulation of APRNs and APMs in Virginia more fair and consistent with other healthcare professionals in the Commonwealth. Thank you, Tana McCoull, CNM, FNP

IN SUPPORT of HB978. Virginians deserve to have faith in their regulatory systems, especially when it comes to health care. The current system is not based in safety, science or public support. Over-regulation delays necessary actions for improving patient outcomes and erodes trust from the public. Midwives practice midwifery. APRNs practice nursing. Midwives and Nurses are the only clinicians with relevant expertise to evaluate, establish and maintain adherence to the standards of practice for their respective fields. No other advanced practice profession is expected to be regulated by an entirely different profession. Please support the move of the professions of advanced practice registered nurses and licensed certified midwives from being licensed jointly by the Board of Medicine and the Board of Nursing to being licensed by the Board of Nursing only.

NPWH is the national professional association and community of Board-certified Women’s Health Nurse Practitioners (WHNP-BCs) and other advanced practice registered nurses (APRNs) who provide women’s and gender-related health care. We set a standard of excellence by generating, translating, and promoting the latest research and evidence-based clinical management, providing high-quality continuing education, and advocating for patients, providers, and the WHNP profession. Our mission includes protecting and promoting women’s and all individual’s rights to make their own choices regarding their health and wellbeing within the context of their lived experience and their personal, religious, cultural, and family beliefs. NPWH gives voice to nearly 13,000 WHNP-BCs in the United States, who provide sex and gender-focused care across the spectrum, from puberty through senescence. Our membership includes WHNP-BCs, certified nurse midwives, family nurse practitioners and other advanced practice providers who support women across their life spectrum. The certified WHNPs and APRNs we serve are recognized experts in the primary, complex and specialty care of women, and are leaders and advocates in the advancement of healthcare towards a more just, healthy, and equitable world. NPWH Workforce Priority WHNP-BCs provide sex and gender-focused care for women from puberty through menopause and beyond. Their care includes primary care, common and complex gynecologic, sexual, reproductive, menopause transition and post-menopause healthcare; uncomplicated and high-risk prenatal, antepartum, postpartum, and interpregnancy care; and sexual and reproductive care for men. Further, the WHNP-BC is the only nurse practitioner population focus to hold enumerated competencies in providing high-risk antepartum and postpartum care that includes advanced assessment, diagnosis, treatment of risk factors, complications, and urgent conditions. They provide and co-manage care for patients with high-risk antepartum and postpartum conditions in collaboration with multidisciplinary teams in inpatient and outpatient settings. A 2012 Rand Corporation study projected a shortfall of WHNP-BCs, a subset of the NP workforce with enumerated competencies in sexual and reproductive health care, as demand for these services rise. Since that time, the number of students entering academic programs in preparation for the WHNP role has remained flat. Further, WHNP-BCs are rarely included in reports of women’s health and maternal health provider shortages, yet many states have relatively few WHNPs. For example, states such as Wyoming (16 WHNPs) and South Dakota (27 WHNPs) have few WHNP-BCs available, thus further limiting access in rural and frontier areas. Lack of recognition of the WHNP-BC as a key provider in women’s and maternal health services creates a “silent provider” and limits incentive to enter the field. NPWH advocates for the recognition of WHNP-BCs as integral to the provision of women’s health care, including maternity care, sexual and reproductive health care, gynecologic care, and care during perimenopause, menopause, and beyond. We recommend that in all APRNs have full practice authority and oversight over their own professions reporting to a Board of their peers.

The American College of Nurse-Midwives represents Certified Nurse-Midwives and Certified Midwives. ACNM supports HB978. This bill will allow midwives and APRNs to be regulated by the board of nursing. Midwives practice midwifery and will have an advisory committee to the board of nursing. Midwives and nurses are the only clinicians with relevant expertise to evaluate, establish, and maintain adherence to the standards of practice for their respective fields. No other advanced practice profession is expected to be regulated by an entirely different profession, as is the case with CNMs and CMs being regulated by a joint board. The VA government has done its due diligence concerning research on this bill, and the Department of Health Professions is recommending this change to a single board rather than a joint board. Virginians deserve to have faith in their regulatory systems, especially when it comes to health care. The current system is not based on safety, science, or public support. Over-regulation delays necessary actions for improving patient outcomes and erodes the trust of the public. ACNM strongly endorses this bill which will increase access to CNMs and CMs, professionals with a proven track record of safety and who reduce the incidence of preterm birth, cesarean births, and low birth weight infants.

This legislation seeks to remove joint licensure of advanced practice registered nurses by the Boards of Nursing and Medicine and solely license advanced practice registered nurses (APRN)s under the Board of Nursing. Current regulations governing Virginia’s APRNs require them to go through an additional and unnecessary layer of approval by the Committee of the Joint Boards of Nursing and Medicine in addition to being licensed by the Board of Nursing. This requirement is incongruent with the national APRN Consensus Model, and the Virginia Department of Health Professions studies from both the Northam and Youngkin administrations, which recommend regulating APRN nurses solely under the Board of Nursing. According to the Department, as is the case in 47 other states, “The Board of Nursing, with multiple APRN Board members, is fully capable of regulating and disciplining APRNs.” The primary legislative change needed is to amend the Virginia Code to eliminate joint licensure and regulation by the Boards of Medicine and Nursing. In 2016, the Federal Trade Commission referred to medical doctors regulating APRNs as anticompetitive, writing: “[w]e urge you to consider whether to allow independent regulatory boards dominated by medical doctors and doctors of osteopathy to regulate APRN prescribing, given the risk of bias due to professional and financial self-interest.The ability to attract and retain nurses in the Commonwealth is paramount to addressing our nursing shortage. Please support the federal recommendation to eliminate the unnecessary joint oversight of the Committee of the Joint Boards of Medicine and Nursing. We are losing providers to less restrictive states!

I write this letter with wholehearted support for House Bills 971, 983, and 978. These bills recognize the importance of empowering advanced practice nurses (APRNs) to self-manage as a profession, and move beyond outdated and unnecessary oversight by physicians. They represent a significant step towards acknowledging the expertise and capabilities of APRNs. HB 971, 983, and 978 will allow APRNs to be competitive with our peers in the District of Columbia and Maryland, localities which have far fewer restrictions on advanced practice nursing, and to whom we regularly lose entrepreneurial nurse practitioners who would rather open their businesses out of state than pay a physician a monthly cut of their business in an arbitrary "collaboration." Thank you for your attention to this matter.

NPWH is the national professional association and community of Board-certified Women’s Health Nurse Practitioners (WHNP-BCs) and other advanced practice registered nurses (APRNs) who provide women’s and gender-related health care. We set a standard of excellence by generating, translating, and promoting the latest research and evidence-based clinical management, providing high-quality continuing education, and advocating for patients, providers, and the WHNP profession. Our mission includes protecting and promoting women’s and all individual’s rights to make their own choices regarding their health and wellbeing within the context of their lived experience and their personal, religious, cultural, and family beliefs. NPWH gives voice to nearly 13,000 WHNP-BCs in the United States, who provide sex and gender-focused care across the spectrum, from puberty through senescence. Our membership includes WHNP-BCs, certified nurse midwives, family nurse practitioners and other advanced practice providers who support women across their life spectrum. The certified WHNPs and APRNs we serve are recognized experts in the primary, complex and specialty care of women, and are leaders and advocates in the advancement of healthcare towards a more just, healthy, and equitable world. NPWH Workforce Priority WHNP-BCs provide sex and gender-focused care for women from puberty through menopause and beyond. Their care includes primary care, common and complex gynecologic, sexual, reproductive, menopause transition and post-menopause healthcare; uncomplicated and high-risk prenatal, antepartum, postpartum, and interpregnancy care; and sexual and reproductive care for men. Further, the WHNP-BC is the only nurse practitioner population focus to hold enumerated competencies in providing high-risk antepartum and postpartum care that includes advanced assessment, diagnosis, treatment of risk factors, complications, and urgent conditions. They provide and co-manage care for patients with high-risk antepartum and postpartum conditions in collaboration with multidisciplinary teams in inpatient and outpatient settings. A 2012 Rand Corporation study projected a shortfall of WHNP-BCs, a subset of the NP workforce with enumerated competencies in sexual and reproductive health care, as demand for these services rise. Since that time, the number of students entering academic programs in preparation for the WHNP role has remained flat. Further, WHNP-BCs are rarely included in reports of women’s health and maternal health provider shortages, yet many states have relatively few WHNPs. For example, states such as Wyoming (16 WHNPs) and South Dakota (27 WHNPs) have few WHNP-BCs available, thus further limiting access in rural and frontier areas. Lack of recognition of the WHNP-BC as a key provider in women’s and maternal health services creates a “silent provider” and limits incentive to enter the field. NPWH advocates for the recognition of WHNP-BCs as integral to the provision of women’s health care, including maternity care, sexual and reproductive health care, gynecologic care, and care during perimenopause, menopause, and beyond. We recommend that in all APRNs have full practice authority and oversight over their own professions reporting to a Board of their peers.

Comments Document

I need to ask you to support Nurse Practitioners in Virginia to be able to practice at the top of their education, certification, and licensure. Virginia is the most restrictive state in regulating nurse practitioners. Currently a NP must be practicing under a physician collaboration agreement for 5 years. We are requesting full practice authority (FPA) after 2 years of practice. The word “collaboration” does not define the relationship between a NP and physician. The relationships are collegial with mutual contributions from both skilled and knowledgeable professions to improve patient care. That has been my experience as a NP of more than 30 years in practice. However, those opposing this progression feel threatened by the removal of the term “collaboration” and a practice agreement. It is a power struggle that is divisive and impacts patient care- the reason we do what we do-to help patients. Their oversight costs NPs and organization’s money. Data shows that NPs are safe and effective health care providers. Collaboration does not cease when a NP receives his/her FPA. Collaboration in health care is common and a known process that we all practice that should not require regulation or mandated statues. Physicians of various disciplines just like NPs know how to “stay in their lane”. A family practice doctor will collaborate with a cardiologist to determine what is the next test or medication to try for a complex patient. NPs do the same. NPs should not have to be regulated to collaborate. It is a standard of practice. Two bipartisan bills HB 971 and HB 983 will reduce the number of years from five to two, which would align Va with most other states with full practice authority (there are states with zero requirement). NPs have an average of 10 years’ experience as a RN before getting their master’s or doctoral degree and the 2 years under the mentorship of an experienced clinician before granting of full practice authority prepares them for the transition. Currently if the physician retires or leaves the office, the NP must scramble to get another practice agreement signed or risk closing the doors. Access to their provider will cease and leave patients, families, and communities without health care. Across the Commonwealth, thousands of patients entrust their care, and their families care to NPs. The FQHC that I work for operates with NPs that practice exceptional standards in delivering care to a rural and vulnerable population. We are committed to sustaining a collaborative and collegial relationship with our physicians. With much gratitude, Dr. Rosie Taylor-Lewis, Doctor of Nursing Practice, ANP-BC, GNP, PMHNP-BC

As a previous member of the Virginia Board of Nursing (VBON) and a faculty member currently teaching in both the graduate and undergraduate nursing education program in an accredited school of nursing in Virginia, I write in opposition to HB 1290. While this bill attempts to address faculty shortages in schools of nursing, it does not address the root cause of such shortages. In 2021, 4,442 applicants were denied admission to nursing programs at the two-year or four-year level in Virginia because the capacity to educate those individuals currently does not exist (AACN, 2022). The current Virginia full-time nursing faculty vacancy rate is 11.8% for baccalaureate programs with the majority of schools reporting clinical faculty vacancies (AACN, 2021). To continue to produce new graduate nurses at the current rate, it is imperative to invest in the infrastructure of both schools of nursing and clinical partners to ensure the availability of qualified faculty, clinical instructors, and preceptors. The inability to recruit qualified faculty and clinical instructors lies not with the educational requirements of faculty but with factors including but not limited to compensation and benefits. According to the American Association of Colleges of Nursing (AACN, 2022) “higher compensation in clinical and private-sector settings is luring current and potential nurse educators away from teaching”. The average salary of practicing registered nurses (RNs) ranges from $80,000 to $139,000 (Nurse.com, 2023). By contrast, AACN reported in March 2022 that the average salary for a master’s-prepared professors in schools of nursing was $87,325. Further, clinical instructors report that they can make more by working an extra shift as compared to teaching a group of nursing students for a full semester. Finally, the VBON, comprised of nursing professionals and citizen members along with a highly trained staff, grant exceptions for educational requirements for nursing faculty. And the VBON is currently in the process of revising the regulations governing nursing education programs with input from education experts to ensure nursing students are properly educated to care for the increasingly complex needs of Virginians. Again, I write in opposition to HB 1290. Thank you for considering my comments. Respectfully submitted by: Theresa Gaffney, PhD, MPA, RN, CNE

I am writing you today to urge you to support HB 1322 for removal of supervision of Certified Registered Nurse Anesthetists (CRNAs). I am a Certified Registered Nurse Anesthetist (CRNA) who practices at a small, rural hospital in Lexington, Virginia. Myself and 3 other CRNAs are the sole anesthesia providers at our hospital. Not only do we administer anesthesia for every surgery performed here, but we are also called upon to sedate patients in the emergency department, place emergency lines in the ICU, and many other duties. We are the only professionals in the building who are trained in anesthesia. Our amazing surgeons, hospitalists, and emergency room physician are experts in their respective fields; however, they have not studied nor have they ever practiced anesthesia. Yet, because of statutes in Virginia they are “supervising” our practice. This makes absolutely no sense. Furthermore, the physicians supervising us generally have no input into my anesthetic care, as it is not their specialty. The reality is that they are supervising in name only and there is no real utility to these requirements. Vene worse we are the only Advanced Practice Registered Nurses in Virginia that have these archaic requirements. In fact, the entire country is moving away from requiring supervision of CRNAs. Virginia is one of the few left with these laws. I urge to please support this bill and make the law match the reality of our practice here.

I am practicing CRNA in the Roanoke Valley, and I support the current legislation in place in Virginia for advance nurse practitioners. I do not support HB 1322 as it does not optimize patient safety.

I am writing this testimony in support of HB1322, the removal of physician supervision for CRNAs. You will hear testimony regarding the benefits of this bill in improving the national anesthesia shortage, so I will focus on what you may not know; the emerging field of evidence-based, integrative mental-health clinics utilizing Ketamine infusion and Ketamine-assisted therapy. Around the country, there are many of these clinics, and the majority are run by highly trained and qualified CRNAs. We are trained down to a molecular level in the medication, ketamine, are proficient at administration, and are qualified airway experts that safe administration requires. These clinics run either with offsite supervision from a medical director or, in many states where supervision is not required, they are owned and operated completely autonomously by CRNA’s. I have partnered with my sister-in-law, a psychiatric Nurse Practitioner, and my wife, an Occupational Therapist who specializes in pelvic health and trauma-integration therapy, to come full circle to my true purpose. Together, we are creating an integrative health clinic in a severely underserved area, Newport News, VA. We will provide evidence-based and holistic treatment for those struggling with mental illness and chronic pain conditions. This includes ketamine infusion therapy, trauma-integration therapy, nutrition counseling and lifestyle medicine. We will also offer free workshops and group therapy sessions for community outreach and support. HB1322 will increase patient access to essential medical services and facilitate additional opportunities for these types of clinics to address the pervasive mental health crisis in our communities. Kind regards, Caleb Lesch, CRNA Illuminate integrative health, inc 212-518-1944 141 Beechwood Hills Newport News, VA 23608

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Hi I am writing to you on behalf of The Well Connection UK, a media and publishing company. We could easily get virginia.gov featured in various publications such as magazines, online blogs and news sites. This would undoubtedly help virginia.gov with publicity, reputation, domain authority and organic search engine rankings. We have a wide range of options including completely free collaborations, sponsored posts, guest posts and banner ads. If this sounds of interest, please reach out to the senior business development manager, Anita at info@thewellconnection.co.uk and whatsapp +447395206515 (GMT) Kind regards Clifton Junior Outreach Assistant

Alexandria is a vibrant city based on history, culture, a waterfront and lots of tourism. If Virginia has money and space to build an arena then you have money and space to build new schools. Our school system is deplorable. It’s overcrowded. Think of your citizens before thinking about your quick money grab that eventually leads to an inevitable loss. We don’t want or need an arena. This is pure greed.

Strongly Oppose

Hi, Im Lydia Figueroa and I’m a nurse educator. As a nurse educator I’m concerned about faculty not being qualified to provide the education needed to teach nurses the critical thinking skills needed to provide quality patient care. Instead of decreasing educational requirements for nursing faculty, could this bill helped secure funding for graduate schools in nursing. It is important that nursing students to gain the knowledge needed to become safe practitioners from highly qualified faculty members. Exactly how will this bill help the body of nursing education, research and practice. Moreover, I do not believe this is the answer for underrepresentation of remote locations or minority health care. Funding more qualified healthcare facilities in those locations will help with that. My final statement reflects upon the large number of nurse educators who were not aware of this bill in a timely manner. Was there a survey or other opportunities for our input? Where did this come from. Nursing should be more respected. We put in the work for our profession and we need to maintain the integrity. Thank you.

I am extremely concerned about the potential change of education requirements. There are potential ramifications they may not have been considered. Where academic nurse educators made aware of this desired change prior to this point?

As a faculty member teaching in both the graduate and undergraduate nursing education program in an accredited school of nursing, I am writing to provide comments to HB 1499. Over the past year, I have worked collaboratively with representatives from nursing education, practice, and regulation to create an actionable strategic plan to address the unprecedented nursing workforce the Commonwealth is experiencing. Yet, critical steps to address the nursing workforce shortage are visibly absent from the current legislation (HB 1499) being considered. Virginia is projected to experience a shortage of more than 20,000 registered nurses within the next ten years, and some models predict that the national nursing shortage will reach more than half a million nurses by 20301. This shortage compromises the health of all Virginians and the stability of the healthcare system in the Commonwealth. While this proposed legislation attempts to address health care provider shortages, it falls short of addressing the needs of preparing a highly educated nursing workforce to care for the increasingly complex needs of Virginians. Therefore, I ask the committee to consider specific actions to amend this bill and address the nursing workforce crisis. One key action is to allocate funds within the Virginia Health Workforce Innovation Fund to: 1. Build a sustainable and more diverse nursing workforce • Launch a Virginia Nurse Educator Academy for new academic educators, clinical instructors, and preceptors. • Prioritize debt forgiveness opportunities for contracted worktime for nurses and expand wrap around services to support nurses in school. 2. Create innovative models of nursing education and practice • Establish a designated fund to support research and development of innovative models of nursing education and practice such as the Earn While You Learn program. 3. Strengthen the Nursing Education Pathway • Establish joint academic/practice (employer) appointments to enhance nursing faculty in schools or nursing. • Standardize student onboarding processes across the Commonwealth to streamline clinical education and reduce institutional burden. 4. Engage the Nursing Workforce through Collaboration and Partnerships • Establish a Virginia Nursing Workforce Center to administer innovation funds and coordinate efforts to educate, recruit, and retain a professional nursing workforce. 5. Retain the Nursing Workforce • Develop a clearinghouse of best practices/exemplars for nursing recruitment and retention and workforce development. In conclusion, investing in nursing education and practice is the pathway to ensuring a stable healthcare system in the Commonwealth. Thank you for your consideration of these important requests. Respectfully, Theresa Gaffney, PhD, MPA, RN, CNE

As one of Virginia’s healthcare workforce educators and leaders, I am writing to support HB 1499. This bill, if passed, has the potential to significantly impact the healthcare landscape in our state and, specifically, the Rappahannock Region, which suffers from extensive health inequities and health workforce shortages. The legislation aims to develop and implement strategies to recruit and retain underrepresented minority and rural populations to join and remain in Virginia’s healthcare workforce.

I am writing to support HB 1499. Passage of this important workforce development bill could significantly allow us to expand strategies to recruit and retain healthcare professionals of all types. Specifically, it would give us the opportunity to impact underrepresented minority, and in the Southwest Virginia area, rural populations. Thank you for all you do!