A Blurred Vision of the Future of CNS Regulation
On February 17, 2006, the National Council of State Boards of Nursing (NCSBN) released a draft vision paper describing what they hope will be the future of Advanced Practice Registered Nursing (APRN). The document is 26 pages long, and the NCSBN gave all professional nursing organizations until March 30, 2006 to provide their comments and feedback to the paper. It is incredible to me that it took an Advanced Practice Advisory Panel 3 years to write the document and they have given nursing organizations less than 6 weeks to respond.
The document discusses some sweeping regulatory changes that the NCSBN feels must take place to make the APRN landscape more consistent, easier to manage, and more easily moved into the multistate compact that they envision is the future of advanced practice nursing. These sweeping changes include some very blurred perspectives that seem to have been generated in the vacuum of regulatory bliss. In other words, "in a perfect regulatory world we would like to see[horizontal ellipsis]" The difficulty with their vision of the perfect regulatory world is that it disenfranchises large portions of the professional nursing world.
Most troubling to me is that the paper describes a world where there are no clinical nurse specialists (CNSs). In the NCSBN's vision of the future, there will be only 3 advanced practice roles: Nurse Practitioners, Nurse Midwives, and Nurse Anesthetists. It defines the scope of practice of an APRN as being solely bound by practice within the medical domain (prescribing medications, performing invasive procedures, etc). It calls into question the ability of the certifying agencies to provide valid and reliable tests that meet the need of regulatory bodies. It also calls into question the ability of accrediting bodies to validate and certify that educational programs have met specified standards. Finally, it proposes rewriting the curriculum of nursing educational programs to include a residency which also discredits the ability of nursing faculty to prepare advanced practice nurses. They have, with this document, successfully angered or disenfranchised almost all of the professional organizations in nursing.
Although the timeline has been short(I am writing this on March 30, 2006), many nursing organizations have stepped up to provide written comments that are unanimously negative. The following is a very abbreviated list of some of the organizations that have provided negative written responses to the NCSBN: The American Association of Colleges of Nursing, the American Association of Nurse Anesthetists, the American Academy of Nurse Practitioners Certification Program, the American Nurses Credentialing Center, the American Association of Colleges of Nursing Certification Corporation, the American College of Nurse Midwives Division of Accreditation, the Associated Faculty of Pediatric Nurse Practitioners, the Collegiate Center for Nursing Education, the National Certification Corporation, the Pediatric Nursing Certification Board, the National Organization of Nurse Practitioner Faculty, the National Association of Nurse Practitioners in Women's Health Council on Accreditation, and your own organization, the National Association of Clinical Nurse Specialists.
The response of the NACNS has been to try to find areas of common interest such as ongoing assessment of competencies, but also to identify aspects of the document where we find flawed thinking and identify where the NCSBN has overstepped its boundaries by proposing changes that are outside the scope of its regulatory domain. Key talking points have been provided by NACNS to its members and others who need information on how best to focus their discussions with their respective state boards of nursing. The key to this issue is that the NCSBN cannot implement the sweeping change they are proposing if each state board of nursing does not adopt the proposal. You have the power to stop this process by speaking out to your state board representatives. You can find these talking points on the NACNS Web site at http://www.nacns.org.
Additionally, the NACNS board has prepared a formal response to the NCSBN that is also available on our Web site. Key issues raised in that document include the following:
* NACNS believes that the NCSBN's Vision Paper does not reflect a clear understanding of nursing practice at a basic or advanced level.
* NACNS firmly believes that the clinical nurse specialist falls within the category of APRNs and should retain their title and status as an APRN.
* NACNS is concerned that those who drafted the Vision Paper put forth an incomplete concept of independent nursing diagnosis and treatment of health conditions.
* NACNS questions the scope of the recommendations in the Vision Paper. State regulatory boards have the authority to set public regulation. This document goes beyond the scope of public regulation to professional oversight and standard development.
* NACNS is supportive of the concept of continued competence for licensure renewal.
* NACNS supports the evolution of APRN practice to a professional practice model that includes collaboration with other healthcare professionals not supervision by another healthcare profession.
The overwhelmingly negative response to the draft vision paper speaks volumes and has galvanized and united many previously confrontational organizations. This document has created what I hope will be a sustained energy that has enabled a sense of collaboration among even the most contentious of professional organization relationships. Perhaps we can move forward together to a more acceptable, common vision of the APRN world. At least the dialogue has begun and we have the opportunity to continue discussions. Let's hope for a brighter future than what the NCSBN has described[horizontal ellipsis]
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