Valued Voice

On Sept. 10, the Wisconsin Board of Nursing (BON) held a public hearing on its 15-page emergency rule order amending multiple Board of Nursing rules affected by the Act 17 APRN Modernization Act.  

During the hearing, WHA General Counsel Matthew Stanford provided a brief overview to the BON about confusion and challenges encountered by advanced practice registered nurses (APRNs) and WHA members regarding the Sept. 1 implementation of Act 17 and the Board’s emergency rule, together with recommendations to address those challenges.

WHA also submitted written comments from Stanford and WHA Senior Vice President of Workforce and Clinical Practice Ann Zenk to the BON elaborating on WHA’s offered oral comments. WHA offered the following recommendations to the Board of Nursing as part of its comment letter:

• Defining collaboration.  Explicitly align collaboration language in N8.10 with Act 17, so that existing APNPs seeking to continue collaborative practice do not mistakenly believe they need to change their collaboration arrangements or scope of practice.  
• Professional standards applicable to all APRNs.  Move applicable professional standards in existing N8 to a new section that applies to all APRNs, whether independent or practicing collaboration.
• Address independent practice criteria confusion.  For independent practice qualification requirements, address disconnects between Act 17 and the emergency rule and application forms regarding hours practicing in collaboration as had been required for APNPs under N8 versus hours practicing in a direct supervision relationship which were not required of APNPs under N8.
• Address confusion regarding licensure requirements for medical malpractice coverage. Although Act 17 codified the same medical malpractice requirements specified for APNPs in N8 as a condition of licensure, there has been some misunderstanding that those requirements have changed for purposes of a licensure requirement. To help ensure APNPs are not purchasing additional coverage not required for licensure as an APRN, the same medical malpractice coverage licensure requirements and language that were required for APNPs in N8.08 and adopted in Act 17 should be retained in N8 for all APRNs.  
• Update delegation standards.  To align with delegation standards for physicians and physician assistants, update the Board of Nursing’s delegation rules to utilize the same delegation language and standard specified in Act 17.
• Establishing professional standards for birth plans for out of hospital births.  Amend N8.047 to align with the birth plan requirements specified in s.441.09(6)(a)6., including approval by the Board, and to establish in rule the Board’s minimum professional standards for ensuring appropriate care and care transitions regarding home births.

The BON will continue working on a permanent rule that will likely modify the published permanent rule, however the timeline for such updates, either on an interim or permanent basis, has not yet been established.

A copy of WHA’s comment letter to the Board of Nursing on the APRN emergency rule can be found here.