Board, 4/24/24 - Board approves.

Heather Farmer-Bailey - The current statue and rules stipulate specific graduate education and clinical experience requirements and professional certification requirements as prerequisites for application for licensure for provisional prescriptive authority. Additionally, employers and
payors require credentialing for services being provided. The requirements of this rule are burdensome and do not reflect my competence as a clinician or prescriber. Rather, they require additional work to complete a “one size fits all” requirement for APRNs. Additionally, these requirements caused undo stress during my transition to practice. The proposed changes to this rule, unfortunately, do no ease the burden of the requirements for obtaining prescriptive authority who are already licensed and board certified.

Ashley Shew, AANP - respectfully requests that the Board not adopt the proposed revisions as written.

Juliet Nygaard - The proposed Rule 1.15 creates confusing and burdensome mentorship
requirements that are not reflective of current employment standards
making retention of APRNs with prescriptive authority in Colorado
tenuous.

Jennifer Plum - The proposed rule changes to rule 1.15 restrict Nurse practitioners that serve both rural/critical access areas and urban
areas. The change does not “make practitioners safer” but rather adds an unnecessary and expensive burden.
Please do not ratify these rule changes.

Monica Bailey - I am reaching out to voice opposition to the proposed changes to Colorado APRN transition to practice requirements to obtain full prescriptive authority both as a future nurse practitioner and concerned colleague of the many providers and medical practices this change will negatively affect.

Kellie Logue, COANA - 1: Inconsistent Use of Terminology in the areas of Definition of Population Focus, which could create confusion and hinder the application process for APRNs. Removal of reference to, “and, if applicable,” in discussions of
Role and Population Focus.

Constance McMenamin - I believe strongly that NP should be allowed to get their 750 mentoring hours in their current practice setting. NPs have graduated from a credentialled academic program, have competency in clinical judgement, and have national certification. The 750 hours is for NPs to gain confidence in prescribing. Clinical practices and patient populations frequently overlap therefore trying to solve for all patients that one may find in our clinic settings is onerous.

Elizabeth McCutchon - I do not agree with the required 750 hours of mentorship for full prescriptive authority. DORA has not provided any evidence that suggests this practice improves patient outcomes. Furthermore, the burden of having to submit one’s mentorship plan to DORA for approval prior to starting the mentorship will delay work start dates for new graduate NPs. This is a deterrent to work in the state as a new graduate. A current goal in health care is to improve access to care. Creating barriers for new NPs will not help improve access to care.

Board, 4/24/24 - Clarification needed.

Colleen Casper, Colorado Nurses Association - At Section (C)(19), the new-proposed definition of Population Focus includes reference to an “area of practice” that cannot fairly be inserted with the other “areas of practice” listed. Specifically, it includes reference to a “gender-related” area of practice.

Ashley Shew, AANP - Suggested Language: C.19. Population Focus: A broad area of study encompassing the common problems of a specific group of
patients and the likely co-morbidities, interventions and responses to those problems including, but not limited to, the following areas of practice: family/individual across the lifespan, adults or gerontology,
pediatrics, neonates, women’s health care/gender-related, and psychiatry and mental health. A Population Focus is not defined as a
specialty, specific disease, health problem or intervention.

Board, 4/24/24 - Changes approved.

Kari Searcy - The proposed rule changes requiring mentorship of certain hours in certain areas is burdensome, and is in fact duplicating already established educational requirements of CRNA educational programs.
What -if any -problems is this rule trying to correct? CRNAs, after passing their boards and completing an accredited program, have certainly already met these requirements, and then some....CRNAs and are safe to practice with FULL Prescriptive Authority and
Full Practice Authority. This proposed rule change will cause an unnecessary financial burden to the APRN RXN applicant, and a time constraint that is duplicative and cumbersome.
This is an unnecessary and bureaucratic rule change that will affect NO additional safety. This in fact could potentially decrease access to safe care for people across our state.

Melissa Chambless - I’m wondering if there’s any thought in dropping the
additional hours required for full prescriptive authority. This requirement is taking providers out of healthcare to fulfill requirements that have already been completed through nurse practitioner school. Not only are providers being taken out of their job so that they may fulfill these additional hours, they are losing money as they are not able to be paid during these hours and are missing work as a result. As mentioned above, these hours have been fulfilled during nurse practitioner school, and we have also proven ourselves able to competently care for and prescribe populations across the lifespan through passing our boards and passing an accredited nurse practitioner program. The hours selected for each individual has seemed rather arbitrary and varies greatly across all individuals. For example, in my place of work, I have found that my coworkers have quite varied requirements for additional pediatric hours although we have the same exact
experience.

Talin Sullivan - I am writing this email to inform you that I do not support part of the proposed revision to draft rule 1.15. Specifically, section G part a, b and c. Section a may create a concern of liability for mentors and section b language "experience
satisfactory to the board" lacks clarity. As for section c, this may create an issue with employers who may be hesitant to hire new NPs due to uncertainty around Board approval for mentorship. The delay in waiting for board review creates a challenge with employers seeking to fill positions quickly.
I am in favor of removing the requirements related to hours of mentorship prescribing within various populations, which I believe has already been removed.

Kaycee Simon, COANA - 2: Documentation Requirement Associated with the Mentorship: Rule 1.15 contains onerous requirements
for documentation pertaining to the mentorship. The proposed language at Rule 1.15, Sections (G)(1)(a), (b), and (c), requires the applicant to submit documentation of completion of mentorship that goes beyond the content of any mentorship form previously used or proposed. In addition we have concerns about Sections G (1) a-c.

Kellie Logue, COANA -
2. Documentation Requirement Associated with Mentorship: The proposed documentation requirements for mentorship hours are overly burdensome and may deter both APRNs and mentors from participating. We suggest revising these requirements to provide clarity and reduce unnecessary regulatory burden.
Section (G)(1)(a). It is not clear to CNA whether the Board intends for the applicant to truly document the 750 hours as contemplated by Section (G)(1)(a), nor how that documentation could be
completed. As proposed, Section (G)(1)(a) appears to require a discussion of each patient prescribed for
during the 750 hours, including, for example, the reasons for the prescribing, the patient’s presentation, and the expectation of the efficacy of the prescribed medication. This would require the prescriptive authority applicant to summarize their progress note for each patient whose care counts towards the 750 hours of mentorship, and to include in that summary more information than what was likely included in the patient’s
progress note.
Section (G)(1)(b). This section similarly goes beyond confirmation of completion of the mentorship by requiring “evidence of experience satisfactory to the Board” that prescribing has been
completed “for patients across the full spectrum of the RXN-P’s role and population focus, regardless of specialty of specialties. These requirements are onerous and vague. CNA is concerned including this language as proposed may result in the Board engaging in the very practice that caused CNA to raise concerns in the first place, i.e., the inconsistent application of hourly mentorship requirements that will, as many commentators
have noted, result in many Colorado APRNs losing their employment.
Section (G)(1)(c). This section is concerning because it indicates the Board will approve a
mentorship before it begins, but fails to identify what, exactly, the mentorship must entail in order to be approved. CNA is concerned about this on many levels and joins in the commenters who have noted that this provision will make near impossible the employment of the new APRN who does not yet hold prescriptive authority.

Stephen A Ferrara (AANP) - Suggested Language: G.1 To obtain Full Prescriptive Authority, the RXN-P must complete 750 hours of documented experience in a Mentorship. The Mentorship shall be conducted with either a Physician Mentor or RXN Mentor [hereinafter referred to as Mentor(s)] as defined in Sections (C)(11) and (C)(12) of Rule 1.15, respectively. The Mentor shall have education, training, experience and practice that corresponds with but need not be identical to the Role and, if applicable, Population Focus of the RXN-P. The Mentorship must be completed within three years after Provisional Prescriptive Authority is granted.

Ashley Shew, AANP - Suggested Language:
G.1 To obtain Full Prescriptive Authority, the RXN-P must complete 750 hours of documented experience in
a Mentorship. The Mentorship shall be conducted with either a Physician Mentor or RXN Mentor [hereinafter referred to as Mentor(s)] as defined in Sections (C)(11) and (C)(12) of Rule 1.15, respectively.
The Mentor shall have education, training, experience and practice that corresponds with but need not
be identical to the Role and, if applicable, Population Focus of the RXN-P. The Mentorship must be
completed within three years after Provisional Prescriptive Authority is granted.

Angela M Ziemba - I strongly believe that such additional mentorship requirements, beyond the 750 hours in one's designated role and population focus as stipulated by statute, are unnecessary. The Board's interpretation, suggesting mentorship should encompass every age group, population, and disease process that one could choose to serve under their license, appears to be overly broad and may impose undue challenges on FNPs choosing primary care. Safe prescribing principles should not be tethered to a specific condition or population.

Megan M. Graeser - I feel the board is missing the main focus of these 750 hours of prescriptive mentorship. The focus should be on basic principles of safe prescribing that can be used in various APRNs roles regardless of population focus. Some of those principles include how to utilize established clinical guidelines, understanding the importance of knowing patients renal and liver function prior to prescribing, evaluating for potential drug
interactions when prescribing any new medication, and using outside resources like clinical pharmacists to help support decision making. These principles are key parts of a prescribing foundation that APRNs will use for years to help guide them in practice with prescribing of medications and treatments.

Stephen A Ferrara (AANP) - G.1 a. For the nurse practitioner (NP) role, the mentorship includes integrated pharmacologic intervention with patient management.

Ashley Shew, AANP - Suggested Language:
G.1 a. For the nurse practitioner (NP) role, the mentorship includes integrated pharmacologic intervention with patient management.
b. For the certified nurse midwife (CNM), certified registered nurse anesthetist (CRNA), and/or clinical nurse specialist (CNS) roles, the mentorship hours must cover the range of practice for the specific role.
c. This Section (G) does not apply to the RXN-P with prescriptive authority and at least 750 hours of prescribing experience in another state, US jurisdiction or United States military
applying for Full Prescriptive Authority as set forth in Section (J)(2) of Rule 1.15.

Ashley Shew, AANP - For the nurse practitioner (NP) role, the mentorship includes integrated pharmacologic intervention
with patient management.

Megan M. Graeser - Prescribing
competence has been assessed by the APRN completing and passing their respective population focused board certification exams. Mentors should have concerns about liability being attached to them if RXN-P they mentored had a prescribing error and then that mentor could held liable for that error is they had to attest to that providers competency in prescribing medications. If that verbiage is left as it stands, it would cause experienced RXNs and physicians to not enter into mentorship agreements with RXN-P candidates. The lack of willing mentors would force capable and often needed APRNs to look for positions in nearby states that do not have any provisional prescriptive authority requirements.

Cindy Coleman, PPRM - The language requiring an attestation that the RXN-P demonstrates “competence” in proposed Sect G.1.a. creates an unattainable mentorship requirement for employers.

Stephen A Ferrara (AANP) - G.1 b. For the certified nurse midwife (CNM), certified registered nurse anesthetist (CRNA), and/or clinical nurse specialist (CNS) roles, the mentorship hours must cover the range of practice for the specific role

Ashley Shew, AANP - For the certified nurse midwife (CNM), certified registered nurse anesthetist (CRNA), and/or clinical nurse specialist (CNS) roles, the mentorship hours must cover the range of practice for the specific role.

Megan M. Graeser - I see the board is trying to avoid RXN-P applications for full prescriptive authority getting rejected after the APRN has completed 750 hours of mentorship. The requirement of submitting a form and documentation regarding the mentorship arrangement before it begins could delay employment start dates for the APRNs or cause the new APRNs to not be employed due to the additional steps required before the APRN can practice in their professional role. How are employers to know if the mentorship is going to be approved and can they wait to hear from the board regarding the mentorship approval to fill the position? How is the APRN seeking provisional prescriptive authority going to explain this mentorship form and process to their future employers?

Stephen A Ferrara (AANP) - G.1 c. This Section (G) does not apply to the RXN-P with prescriptive authority and at least 750 hours of prescribing experience in another state, US jurisdiction or United States military applying for Full Prescriptive Authority as set forth in Section (J)(2) of Rule 1.15.

Cindy Coleman, PPRM - While we appreciate the intent to notify RXN-P whether the submitted mentorship documents will meet the Board’s requirements prior to completion of the mentorship, proposed Section G.1.c. creates uncertainty that will discourage health care providers from hiring new graduates. Because an RXN-P has already obtained employment by the time the mentorship paperwork is submitted, the RXN-P and employer would be making employment based on their best understanding of the mentorship requirements. However,
there is no guidance as to what standards the Board will apply to any given mentorship. As a result, prospective employers including PPRM would be less inclined to hire new graduates. Colorado – particularly its medically underserved rural communities – would become less attractive to new graduates and the already strained labor market for nurse
practitioners would no doubt become even tighter.
PPRM requests that if the Board will be applying particular standards to mentorship beyond the completion of the required number of hours, that those requirements be published so
that employers and RXN-Ps have certainty in the hiring process.

Ashley Shew, AANP - This Section (G) does not apply to the RXN-P with prescriptive authority and at least 750 hours of prescribing experience in another state, US jurisdiction or United States military applying for Full Prescriptive Authority as set forth in Section (J)(2) of Rule 1.15.

Board - 1/24/2024 - move "c" into "a" position for reorder

Ashley Shew, AANP - Suggested Language:
G.4: The RXN-P and the Mentor(s) shall provide documentation of the successful completion of the Mentorship as requested by the RXN-P to complete an application to obtain Full Prescriptive Authority. The Mentor(s) shall not, without good cause, withhold his/her signature or otherwise fail to attest to the completion of the Mentorship. Upon submission of the application the RXN- P may be granted Full Prescriptive Authority.