Veteran's Health Administration Proposed Rule: Advanced Practice Registered Nurses

Director, Regulations Management (02REG)
Department of Veterans Affairs
810 Vermont Avenue NW
Room 1068    
Washington, DC 20420

Re: RIN 2900-AP44-Advanced Practice Registered Nurses

To Whom It May Concern:

The American Psychiatric Nurses Association (APNA), the largest organization representing the interests of more than 130,000 psychiatric-mental health nurses in the United States, applauds the Veterans Health Administration (VA) for advancing a regulatory proposal that will provide Veterans full and direct access to advanced practice registered nurses. The effect of this proposal is to authorize the VA to allow a covered nurse to practice to the full scope of the nurse's practice, as defined by the applicable national professional association, under a set of VA-approved privileges, regardless of the state in which VA employs the covered nurse. The proposal defines a "covered nurse" as an advanced practice registered nurse who is employed by the VA as a: nurse midwife, nurse practitioner (NP), certified registered nurse anesthetist, or  clinical nurse specialist (CNS).

APNA wishes to emphasize that while CNSs and NPs have separate roles outside of psychiatric-mental health nursing, that within psychiatric-mental health nursing CNSs and NPs have a shared scope of practice. Both are prepared at the graduate level in research, systems, and direct patient care to provide psychiatric evaluations and treatment, including psychopharmacological interventions and individual, family and group therapy, as well as primary, secondary and tertiary levels of prevention across the lifespan. Both are a vital part of the workforce required to meet increasing population mental health needs. APNA’s position is that "psychiatric advanced practice nurses (APRN-PMH), whether they practice under the title of CNS or NP, share the same core competencies of clinical and professional practice. While the individual APRN-PMH may actually implement portions of the full scope and practice based on their role, position, description, and practice setting, it is importantly, the full breadth of their knowledge base that informs their practice" (ANA, APNA, ISPN, 2007). An extensive logical job analysis comparing the two roles, conducted by the American Nurses Credentialing Center and APNA, supports this position (Rice, Moller, DePascale & Skinner, 2007).

Failure to recognize the full scope of practice of the psychiatric-mental health clinical nurse specialist causes the VA to fail to recognize 50% of the PMH-APRN workforce, which in turn will have a chilling effect on the underlying intent of this proposed rule: to help ensure that our Veterans receive the safe and effective care they need from highly trained professionals. 

Be Safe,
Nicholas Croce

Nicholas Croce Jr., MS
Executive Director 


American Nurses Association, American Psychiatric Nurses Association, & International Society of Psychiatric-Mental Health Nurses. (2007). Psychiatric-mental health nursing: Scope and standards of practice. Silver Springs, MD: American Nurses Association.

Rice, M. J., Moller, M. D., DePascale, C., & Skinner, L. (2007). APNA and ANCC collaboration: achieving consensus on future credentialing for advanced practice psychiatric and mental health nursing.Journal of the American Psychiatric Nurses Association, 13(3), 153-159.

The American Psychiatric Nurses Association is accredited with distinction as a provider of continuing nursing education by the American Nurses Credentialing Center's Commission on Accreditation.