PEDIATRIC ASSOCIATION OF
NATIONAL NURSE PRACTITIONERS
NAPNAP
856-857-9700
FAX: 856-857-1600
www.napnap.org
Donna Dorsey, MS, RN, FAAN
President
National Council of State
Boards of Nursing
Dear Ms. Dorsey;
The National Association of
Pediatric Nurse Practitioners (NAPNAP) is committed to working with the
National Council of State Boards of Nursing (NCSBN) to ensure that advanced
practice pediatric nurses provide safe, high-quality care to children and their
families. We are pleased to see that the NCSBN shares these values and is
working to articulate them in your paper, Vision Paper: The Future Regulation
of Advanced Practice Nursing. This letter is NAPNAP's
response to the Recommendations 1-8 on page 17-19 of the document.
We agree with, and support,
Recommendations 1, 4, 6, 7 and 8.
However, we have grave concerns and oppose Recommendations 3 and 5.
Further, most professional documents addressing advanced practice nurses (APN)
in the last five years have included clinical nurse specialists (CNS) in the
definition of an APN. We are opposed to removing CNS from the classification in
this document, as well as language that grandfathers
current CNS's as nurse practitioners.
Overall response: NAPNAP has
confidence in the education and certification processes that have prepared
pediatric nurse practitioners (PNPs) for the past 35
years. Academic institutions and certification bodies maintain rigorous
programs with high standards, resulting in excellent practice by PNPs, who serve thousands of children and families daily.
Currently, master's programs in nursing that prepare nurse practitioners
operate under a set of standards as outlined in the American Association of
Colleges of Nursing(AACN) Master's Essentials and the National Organization of
Nurse Practitioner Faculties (NONPF) nurse practitioner competencies developed
and endorsed by professional nursing organizations and accrediting bodies.
Indeed, educational programs are evaluated and accredited according to their
compliance with these educational standards. As nurse practitioner education
moves to, and adopts, the practice doctorate (DNP), there are higher
expectations of what the essential content and competencies must be.
Accordingly, AACN and NONPF have developed drafts of the DNP Essentials and the
DNP competencies that complement and build on those standards that are already
in place. NAPNAP stands ready to help disseminate this important information to
all Boards of Nursing members.
Recommendations 1, 4, 6, 7
and 8: We strongly support your recommendation that Boards of Nursing be the
sole regulators of advanced practice nursing. It is important to the status of
a profession that the profession itself is the most knowledgeable and most
qualified to regulate its practice. The categories of nurse anesthetist, nurse
midwife and nurse practitioner are easily recognized by the public and other
health professionals for their unique knowledge base, education and scope of
practice, so we concur with your second recommendation. NAPNAP firmly believes,
as you do, in the importance of established educational requirements for
advanced practice and therefore supports your fourth recommendation. Since
1979, NAPNAP has engaged in providing outstanding continuing education and has
endorsed certification for all PNPs as a public
statement of our belief in the importance of continued competency. Indeed, we
appreciate the 40 states and
Recommendation 3: We are
gravely concerned with the use of the word “approve.”
NAPNAP agrees that Boards of
Nursing should recognize programs that are accredited by CCNE or NLNAC. While periods of accreditation may extend
over several years, CCNE and NLNAC require yearly updates and notification of
any substantial changes in programs of study.
Access to information regarding the status of programs whose
accreditation is challenged, or those not approved, is public knowledge. Therefore, it is absolutely unnecessary for
licensing boards to evaluate the adequacy of APRN programs.
Recommendation5: As stated in
our
We strongly and steadfastly
oppose the addition of any residency program requirement; titis already exists in our
advanced NP programs. APRN students are currently required to have supervised
clinical experience in their area of specialty that meets the standards set by
the Department of Health and Human Services, NONPF, AACN, and NP certification
organizations. Concurrent integration of didactic and clinical practica in educational programs, as currently structured,
is pedagogically sound and provides the foundation for highly effective,
autonomous and safe practice. High quality care, provided by NPs, has been
substantiated by a growing body of research.
Over-regulation and unnecessary barriers do not promote the continued
evolution of advanced practice nursing, nor do they assist in attracting nurses
to avail themselves of
graduate education. We have a system that has been successful
and responsive to health care needs in the past and is being refined to address
APN practice in the future with the implementation of the doctorate in nursing
practice. AACN, NONPF, professional organizations, academic institutions and
health care organizations are currently working collaboratively on standards
for education and competencies to ensure safe and effective care; and in
preparing leaders who will help structure our health care systems of the
future. APRN competencies are readily available to the public; a public
education campaign may well serve the public better than additional and
unnecessary regulation.
In conclusion, NAPNAP is in
support of many of the recommendations put forth in the Vision Paper: The
Future Regulation of Advanced Practice Nursing.
However, we cannot ignore the serious consequences that would result if
recommendations three and five were adopted.
We would be happy to work with you on a mutually agreeable solution to
the issues that we have identified. We
look forward to an ongoing dialog to resolve our concerns.
Sincerely,
JoAnn Serota, MSN, RN, CPNP
President
& Fellow
The National Association of
Pediatric Nurse Practitioners