ANNA responds to the preliminary draft of the APRN Vision Paper formulated by the National Council of State Boards of Nursing

March 30, 2006

Nancy Chornick, PhD, RN, CAE

Director of Practice and Credentialing

National Council of State Boards of Nursing

111 E. Wacker Drive Suite 2900

Chicago, IL  60601-4277

Dear Dr. Chornick,

The American Nephrology Nurses Association (ANNA), representing 12,000 registered nurses is pleased to respond to the preliminary draft of the VISION document formulated by the National Council of State Boards of Nursing. ANNA has been an active participant in the APN stakeholder meetings hosted by ANA and the AACN in 2004 and 2005. Our membership includes a relatively small but very active and important cadre of advanced practice nurses – both nurse practitioners and clinical nurse specialists. Four of our current nine members of our Board of Directors are APNs.

We have distributed the draft to our leadership for comment. We have received many thoughtful responses with varied reactions and concerns. None disagreed with the 12 premises for APRN regulation and there was great support for the majority of the recommendations. There was unqualified support for the independence from physicians in both licensure and oversight as well as for the freedom to practice across state lines that would be made possible by a licensure compact between all states. Divergence of opinion was evident, however, in the proposal re the categories and education tracks.

There was little discussion or disagreement about the nurse anesthetists or midwives. Several responders agreed that the overall proposal for the simplification of the nurse practitioner role was appropriate but there was concern over the deletion of the CNS role, even though there was general agreement that the role is poorly defined and highly variable. Many feel that deleting the CNS role devalues and even negates the considerable contribution that CNSs make to nursing and patient care. The other major concern was the incorporation of the DNP track as alternative educational preparation to the Masters degree. This prompted comments that it was both inappropriate and would lead to the same confusion of educational preparation that we have for the RN licensure.

ANNA recognizes the huge amount of thoughtful work that has gone into the creation of this document and applauds NCSBN for their courage to elucidate their vision. We are in wholehearted agreement with your statement:

The challenge of the future lies in creating these areas of clarity while ensuring minimal competency to protect the public without disenfranchising those currently practicing or currently committed to study in areas identified as less broad in nature.

And it is because we join you in wanting to meet this challenge that we offer the following comments for your consideration.

ANNA has experienced first hand the ongoing divisiveness created by the entry in practice (EIP) quagmire because we have taken the position that the BSN is the EIP for RNs and we have made that the eligibility criterion for our certification for nephrology nursing. We applaud NCSBN’s attempt to avoid the same fate for entry into advance practice (EIAP). We agree that the VISION gives nursing a unique opportunity to not make the same mistake twice. However we believe the VISION can be improved upon.

We think that nursing must simplify the EIAP to one core education model, exam, and licensure that includes all APNs whether they plan to be CRNAs, CNMs, NPs, or CNSs. There are some who are concerned that this is the medical model. However, we know that all other professions including pharmacists, lawyers, physical therapists, among others, have one uniform educational preparation – only nursing doesn't, at any level.



Therefore we think there should be one Masters level core course that covers all the requisite knowledge required for advanced practice nursing including nursing theories, pathophysiology, assessment, pharmacology etc building on the BSN (might encourage more RNs to get BSN too) followed by a state licensing exam and giving the credential of APRN. ANNA doesn’t believe it necessitates an internship even though we have had mixed response to that piece of the VISION. Then, (and only then) the APRN can choose specialty training and certification in whatever mode of APN or specialty he/she desires. The majority of specialties already have certification in place but the beauty of the single core model is that this is something the public, other professions, and all of nursing can relate to. It will reinforce all the good evidence we have about APN safe and effective care and additionally it will provide clear direction for potential nurses of the future who need clarity on why nursing is a great profession for the talented, intelligent, caring individual. This model should also reassure other health professions such as medicine that we are not trying to impinge on their practice but rather assure them that nursing can be practiced safely and effectively at an advanced level independent of, but collaborating with, other health care professionals.