February 17, 2014
Kathleen L. Apple MS, RN, CAE, FAAN
Chief Executive Officer
National Council of State Boards of Nursing (NCSBN)
111 East Wacker Drive, Suite 2900
Chicago, IL 60601-4277
On behalf of APNA and the APNA Advanced Practice RN Council we submit this feedback in response to the invitation to submit comments on the revised Proposed APRN Compact Model Legislation and Proposed APRN Compact Model Rules. Some of these comments have been submitted by the individuals using the link you provided:
Language is very confusing and contradictory:
g. states "...is authorized to assume responsibility and accountability for patient care INDEPENDENT of a supervisory or collaborative relationship with a physician. This authority may be exercised in a home state and any remote state in which the APRN exercises compact practice privileges." I understand the intention of the compact is not to grant expanded scope of practice, but that is unclear in this article. Perhaps restate: "The APRN is authorized to assume...according to collaborative/supervisory practice requirements for the state in which they are practicing." This language continues in "Proposed Compact Rule II" "Authorizes independent practice..." and "Rules may be adopted by the Interstate Commission ...without a requirement that rules be ratified by individual states."
Agree with "Key elements" document ("Prescriptive Authority and Independent Practice") "...the potential that the inclusion of these provisions could result in limited adoption of the Compact among other states." It seems premature to push this item as so many state bills regarding independent practice have gone down to defeat.
General comment from one of the members of the Advanced Practice Steering Committee:
I moved to Delaware from Tennessee in 2012 after practicing for quite a few years- it took 1 full year to transfer all licenses and convince the DE Board of Nursing that yes, I am capable and experienced and educated enough to practice here! The idea of having some uniformity from state to state is very appealing.
General comment: With laws requiring differing levels of physician supervision-who supervises the NP across state lines? We can anticipate strong opposition from physician groups who may be concerned about (perceived) liability.
More question than comment: The NLCA timeline document from 2012 states that in 2002, the NCSBN approved model language: "only those states that have adopted RN and LPN/VN NLC may implement compact for APRNs." The 2014 summary document states "it may be politically more feasible for some states to adopt the APRN Compact than the NLC." Wondering how this will work in a state where the APRN practices under his/her RN license-i.e. there is no APRN license?
Thank you for extending this opportunity to APNA members.
Nicholas Croce Jr, MS
American Psychiatric Nurses Association
Download PDF of Letter | APRN Compact Webpage