National Black Nurses Association
NBNA Submits Comments to the VA Proposed Rule Allowing APRNs Full Practice Authority

July 14, 2016
The Honorable Robert McDonald
Secretary of Veterans Affairs
U.S. Department of Veterans Affairs
810 Vermont Avenue, NW
Washington, DC 20420

Re: AP44 - Proposed Rule - Advanced Practice Registered Nurses

Dear Secretary McDonald:

On behalf of the National Black Nurses Association (NBNA), I am writing to support the Department of Veterans Affairs' (VA) proposed rule, Advanced Practice Registered Nurses ( 81 Fed. Reg. 33155, May 25, 2016 ) which takes an important step in allowing our nation's Veterans direct access to high quality health care delivered by APRNs (nurse practitioners, certified registered nurse anesthetists, clinical nurse specialists and certified nurse midwives).
As you know, over 6,000 APRNs currently provide a full range of services to our veterans in the VHA.  Implementation of this rule would expand access to high quality health care and improve the VA's capacity to provide the timely, effective and efficient care that they have earned. This proposal is consistent with the evidenced based recommendations advanced by the Institute of Medicine (now the National Academies of Sciences, Engineering, and Medicine, Health and Medicine Division) in its 2010 report, The Future of Nursing: Leading Change, Advancing Health .

This proposal would standardize care across the VHA and remove burdensome regulatory requirements. The available evidence shows that these restrictions do not lead to improved healthcare outcomes, but do limit access to care. The proposal also aligns with current APRN policy in the Army, Navy, Air Force, Combat Support Hospitals, Forward Surgical Teams and Indian and Public Health Services. APRNs are skilled practitioners who increase access to care, reduce cost, and promote quality. The proposal would grant the VHA with flexibility to fully utilize all providers within the healthcare team, maximize the effective use of resources, and provide optimal care for the men and women who have served our country in uniform.

This rule will ensure that our nation's veterans receive the high quality health care that they have earned. I urge the VA to finalize and implement the proposed rule. Thank you for your consideration of this important matter.

Eric J. Williams, DNP, RN, CNE