All Public comments received

Comment on Rule: 409. Active Duty Military Personnel or Their Spouses
Jacqueline Rychnovsky, Commissioned Officers Association of the US Public Health Service, Landover, MD, submitted 5/22/2020 10:27 AM CT
We sincerely appreciate the language proposed for the federal and active duty nurses and would like to request an administrative change to the wording so that nurses serving on active duty in the U.S. Public Health Service (USPHS) Commissioned Corps will be eligible for federal compact licensure. Uniformed nurses (and their spouses) in the Commissioned Corps of the UPSHS, much like nurses serving in the Navy, Army, and Air Force Nurse Corps, move around the country for various assignments during their careers. USPHS nurses are all commissioned officers of one of our country’s eight uniformed services, receiving the same pay, benefits, and allowances as nurses in the Navy, Army, and Air Force. They are veterans under federal law, recognized by the Veterans Administration as such, and are entitled to the licensure change which you are advocating. When entering active duty, USPHS Officers, whose salaries are paid by the federal government, are required to select a Home of Record for pay and voting purposes which stays with them throughout their career. Public Health Service officers are protected under the Servicemembers Civil Relief Act (SCRA) with provisions to ensure equal protection with state laws based on residency. If the NLC were to include language that would include USPHS Officers, this would help to ensure that they are protected when their physical residency changes and would be very appreciated by the more than 1,500 Public Health Service Nurse officers. Spouses of uniformed officers also make many sacrifices, and this change would allow them to gain employment more quickly as they move around the country in support of their spouse’s service. Although some states provide expedited licensing to uniformed officer spouses, certain states use the language "armed forces" or "military" which can cause spouses of PHS Officers to be barred from this licensing benefit. Including PHS spouses by using the language "Uniformed Service" would provide a great benefit to officers and their spouses. Below are two requested changes. 1. Please change the title of Section 409 “ACTIVE DUTY MILITARY PERSONNEL OR THEIR SPOUSES” to “ACTIVE DUTY UNIFORMED PERSONNEL OR THEIR SPOUSES” and consider the following language change: “An active duty uniformed service member, or his or her spouse, shall designate a home state where the service member or spouse has a current license in good standing.” 2. On the Fact Sheet titled “2018MilitaryFactsheetFINAL.pdf” with the heading is “What You Need to Know: Federal/Military Nurses and Spouses.” Our request is to change the title to “What you Need to Know: Federal/Uniformed Service Nurses and Spouses. https://www.ncsbn.org/2018MilitaryFactsheetFINAL.pdf Overall, changing the word “military” to “unformed service” in all documents would be greatly appreciated. Under Title 5 (Section 8331), and Title 50 (Section 511) of the U.S. Code, commissioned officers of the USPHS are considered by law to be military servicemembers. On behalf of all uniformed nurses, thank you for considering this request.
Comment on Rule: 409. Active Duty Military Personnel or Their Spouses
Jennifer Pluid, Honolulu, HI, submitted 5/5/2020 6:44 PM CT
As a military spouse that changes states every couple years, I support this ruling. This change could not only save military families hundreds of dollars every year (or every couple years), but this ruling could allow them to have greater continuity in their ability to provide care.
Comment on Rule: 502. Dispute Resolution
Nathan Goldman, Kentucky Board of Nursing, Louisville, KY, submitted 4/20/2020 12:08 PM CT
As Rule 502 is presently written, there is a transition between the different levels of dispute resolution: informal resolution to mediation to arbitration. The amendment to subsection (2) eliminates the clear transition from informal resolution to mediation. What is the purpose of the recommendation of the Compliance Committee? Do the parties get to comment on it? Are they required to follow it? It is also unclear what role the Executive Committee has to resolve the dispute if the parties fail to resolve it. Is the Executive Committee supposed to make a ruling? Does that resolve the issue or may the parties go to the next step regardless of what the Executive Committee decides? When is there finality as to the inability to resolve the issue so as to allow the parties to seek mediation? I suggest that the Rule be further amended to clarify its intent.
Comment on Rule: 409. Active Duty Military Personnel or Their Spouses
Rachel Mendiola, Fort Campbell, KY, submitted 4/17/2020 5:04 AM CT
I agree with this ruling is it allows active duty spouses/dependents to work upon moving to an new duty station (state) without the required FBI fingerprinting, background check, etc. The wording in the ruling appears vague.
Comment on Rule: 409. Active Duty Military Personnel or Their Spouses
Laurie Isaac, Highland Park, IL, submitted 4/16/2020 7:22 PM CT
looking to endorse in another state
Comment on Rule: 409. Active Duty Military Personnel or Their Spouses
Julie Barnes, CA, submitted 4/15/2020 12:59 PM CT
Please consider extending this to spouses of employees of US Federal Government agencies who have Foreign Service Corps (such as the Department of State, USAID, etc.). We are a small group but are also impacted by frequent moves (under USG transfer orders) and spend a majority of our careers overseas.
Comment on Rule: 408. Federal Criminal Records
James Hilliard, self, Decatur, IL, submitted 4/10/2020 11:35 AM CT
I am an RN who has worked in several states and has been granted a license in IL, FL, SC, TX, and AZ. In each state, I had to submit fingerprints to the FBI who holds a misdemeanor criminal record on me from 45 years ago. After assessing my petty record, each state's board of nursing happily granted me a clear and unencumbered license. In AZ, I had to go before a disciplinary panel over this ancient record. The members on the panel were even vexed by a nurse having to go through their process over such petty, old, and irrelevant history. Fine, I passed, but why must I be required to face these petty charges over and over. Records of misdemeanors should vanish at some point. I was not given a life sentence.
Comment on Rule: 409. Active Duty Military Personnel or Their Spouses
Marcus Beauregard, Defense - State Liaison Office, Department of Defense, Alexandria, VA, submitted 4/7/2020 1:34 PM CT
The Defense - State Liaison Office (DSLO) works with State governments on behalf of Service members and their families. A key issue for military families, and consequently the Department of Defense, is occupational license portability for military spouses. Approximately, 53% of the 130,000 military spouse who require a license to work are in allied health occupations, and nursing represents the largest portion of this percentage. Additionally, the Department of Defense recognizes that interstate compacts for occupations represent reciprocity for military spouses. The Nurse Licensure Compact (NLC) represents a clear benefit for military spouses; however, because military spouse have different circumstances regarding their legal residence and mobility from their civilian counterparts, the proposed change will allow military spouses to have an equal access to the benefits of the NLC as their fellow nurses. The proposed language of rule 409 is substantially similar to the language in the Audiology and Speech-Language Pathology Interstate Compact and the language being incorporated in draft compacts for mental health counseling and occupational therapy. This language is being considered as the standard approach for military spouses. DoD staff members and leaders, Service members, and military spouses have expressed to me that they recognize the importance of this change for military spouse nurses. Collectively, we express appreciation for this important change.D
Comment on Rule: 408. Federal Criminal Records
Kristen Crane, Wichita, KS, submitted 4/7/2020 11:47 AM CT
I am not a lawyer, and this particular portion seems to be hard to understand. I think what it's saying is that once a nurse has an eNLC any board of any state may not request an FBI background check on the licensed nurse. If this is what its saying then yes, I agree with this position. However, I would like to see layman's terms written here for the public to be able to understand better what you guys are doing.
Comment on Rule: 409. Active Duty Military Personnel or Their Spouses
Jared Vega, Watertown, MA, submitted 3/25/2020 12:18 PM CT
Please make sure that this rule includes United States Public Health Service Commissioned Corps and NOAA Commissioned Corps Active Duty service members. They are uniformed service members that provide public health and healthcare across the country and are often left out due to language that states military or armed forces. Please make sure to use language that says Active Duty Uniformed Service members to ensure inclusion of these two services. For more info about the USPHS please see www.usphs.gov
Comment on Rule: 409. Active Duty Military Personnel or Their Spouses
amber l, HI, submitted 3/23/2020 3:31 PM CT
Active duty families move around a lot. Applying and waiting for states licensure takes a lot of time. During that transition, many spouses are unable to help support the family. This proposition is not enough; we need licensure ability in all states (i.e. compact permission for all states).
Comment on Rule: 409. Active Duty Military Personnel or Their Spouses
CHRISTINA BRADDOCK, US ARMY, DENVER, CO, submitted 3/23/2020 2:56 PM CT
US ARMY ACTIVE DUTY 8 YRS RECENTLY HONORABLY DISCHARGED 25OCT2019. LOOKING FOR ED NURSE POSITION DURING COVID-19 CRISIS. I HAVE CO SINGLE STATE LICENSE. LOOKING TO CHANGE TO COMPACT STATE.
Comment on Rule: 408. Federal Criminal Records
Andrea W, AZ, submitted 3/23/2020 11:40 AM CT
Hello, I am not a nurse I am a patient submitting a request on behalf of nurses that have licenseS but are limited due to probation. These nurses urgently want to help our nation during this pandemic. I hope the board can consider for all states. We currently have active nurses on ATD or disciplines like probation but due to COVID-19 we are low on healthcare professionals. Can the board consider lifting these probations so that more nurses can apply without work restrictions. This can help support our country and increase the availability of more nurses. I understand some on probation may be at high risk but please consider any incidents that are 5 years old to be lifted. Example if a nurse is on probation to due to a DUI that happened 5yrs ago please lift the probation so they are not limited to support us. If this isn’t enough ask the nurses get an evaluation done before the probation is lifree, but due to evaluation being very expensive and to reduce the stress on financial difficulties I would not prefer this method unless a evaluation was needed. Please consider lifting these probations to get the help we need.
Comment on Rule: 408. Federal Criminal Records
Kay Hanneman, Naples, FL, submitted 3/23/2020 10:57 AM CT
Nurses need to have full disclosure on any/all criminal records when being considered for compact license. Have a clean record if you want a compact license. Kay Hanneman RN
Comment on Rule: 409. Active Duty Military Personnel or Their Spouses
Arcadia Chinn, GA, submitted 3/19/2020 10:18 PM CT
I agree with the proposed rule and feel that it will be the best action for military family.
Comment on Rule: 502. Dispute Resolution
Greg Harris, AZ, submitted 3/16/2020 11:58 AM CT
502. DISPUTE RESOLUTION. (1) General. If two or more party states have a dispute, the parties shall attempt resolution following the steps set out in this rule. (2) Informal resolution The parties shall first attempt informal resolution. The Compact Administrators in the states involved shall contact each other. Each Compact Administrator shall submit a written statement describing the situation to the other Compact Administrators involved in the dispute. Each Compact Administrator may submit a response. The submission of the statement and the response shall be in a mutually agreed upon time frame. If the dispute is related to an interpretation of the Compact, the parties shall request assistance from the Executive Committee. If all issues are resolved, no further action is required and all party state Compact Administrators shall be informed of the result. If any issue remains unresolved, the parties shall notify the Commission and request mediation and provide the Compliance Committee with a concise statement of each unresolved issue and analysis including references to NLC statutes, rules and any supporting documents. After review by the Compliance Committee, its recommendations will be sent to the parties and the Executive Committee for further review. (3) Mediation (a) A party state that has a dispute with one or more other party states shall attempt mediation of issues unresolved by informal resolution, Mediation shall be conducted by a mediator appointed by the Executive Committee from a list of mediators approved by the National Association of Certified Mediators or as agreed to by all parties. If all issues are resolved through mediation, no further action is required. If mediation is unsuccessful, the parties shall submit to binding dispute resolution. (b) The costs of mediation shall be shared by all party states involved in the dispute. (c) All party state Compact Administrators shall be notified of all issues and disputes that rise to the mediation stage in order to comment on those matters and disputes that may impact all party states. (4) Binding Resolution or Arbitration (a) Resolution by the Commission. If a dispute between party states unresolved by informal resolution or mediation, the party states shall submit to binding dispute resolution. The parties may choose binding dispute resolution either by submitting the dispute to the Commission for final action. (b) Resolution by Arbitration. As an alternative to final action by the Commission, all party states involved may agree to binding arbitration. In the absence of agreement to arbitration, the matter shall be referred to the Commission for final determination.
Comment on Rule: 409. Active Duty Military Personnel or Their Spouses
Greg Harris, AZ, submitted 3/16/2020 11:57 AM CT
409. HOME STATE DESIGNATION BY ACTIVE DUTY MILITARY PERSONNEL AND SPOUSES An active duty service member, or the member’s spouse, with a current license in good standing shall designate a home state. . The service member or spouse may retain the home state designation while the service member is on active duty. After designating a home state, the service member or spouse shall only change home state through application for licensure in the new state.
Comment on Rule: 408. Federal Criminal Records
Greg Harris, AZ, submitted 3/16/2020 11:56 AM CT
408. FEDERAL CRIMINAL RECORDS Communication between a party state and the Commission and communication between party states regarding verification of the nurse’s eligibility for licensure pursuant to the Compact shall not include criminal justice record information as defined in 28 C.F.R. 20.3 relating to a federal criminal records check performed by a member board under Public Law 92-544.