The Clinical Nurse Specialist Advisory Committee and Board of Registered Nursing staff on Jan. 16 reviewed draft regulatory language that would define the CNS title, the application process and oversight of CNS education programs in California.

Board staff and committee members discussed two primary paths: (1) codify a BRN academic-approval pathway that would allow graduates of board‑approved California CNS programs to obtain a CNS certificate without national certification (commonly called “Method 1”), or (2) require national certification as the only route to licensure. Board Executive Officer Loretta Melby told the committee that Method 1 currently exists informally but “is not codified in statute or regulations,” and that formalizing Method 1 would require the board to define BRN approval and a scheduled review process for approved programs.

Why it matters: the choice affects students, programs and licensing. If BRN approval is required, California schools offering CNS programs would need BRN review and routine ongoing monitoring (on‑site visits and periodic reapproval); if BRN does not adopt an approval pathway, Method 1 would disappear and the board would license only on national certification. Melby warned that either approach will change how the board interacts with CNS programs and will require regulatory detail for the Office of Administrative Law and DCA legal review.

Key details and debate included whether program directors must hold a CNS certificate, how preceptor standards should be set, and how specialty versus population focus is regulated. Staff said BRN currently reviews prelicensure nursing programs on a five‑year basis (or per accreditor schedule) and that the CNS rules would likely mirror nurse practitioner program oversight if the board adopts a BRN‑approval pathway. Committee members and attendees raised concerns that strict national‑certification‑only rules could reduce access to CNS licensure and impede the profession; others urged clarity so employers and the public understand who may properly use the CNS title.

Public comment and stakeholders: Cheryl Goldfarb Greenwood, a clinical nurse specialist and former president of the California Association of Clinical Nurse Specialists, urged the committee not to eliminate Method 1. She said she had tracked BRN registry data since 2015 and that CNS numbers “have declined significantly,” reporting that membership fell from “over 3,500” in 2015 to “a little over 3,000” currently. Greenwood warned that removing Method 1 could create barriers to patient access and to the profession’s viability.

Board staff and subcommittee members said the draft regulation language (materials begin on page 15 of the packet) is an unedited submission from the subcommittee and has not yet been vetted by the DCA regulatory attorney or finalized by BRN legal. Marissa Clark, described in the meeting as a BRN legislative/legal chief, is reviewing the language, and further editing will be required before formal Board or public posting.

Scope, specialty and practice: staff reiterated that as regulators they can define population focus (for example, adult‑geriatrics, pediatric, neonatal) but generally do not regulate subspecialty certifications (for example, oncology or cardiology CNS specialty credentials). Committee members discussed whether a CNS certified in one population could practice in another clinical area if competent and supervised by employers—an approach BRN staff compared to existing NP practice where employment and competency, not statutory specialty limits, often determine where clinicians work.

Preceptors and program operations: committee members raised practical concerns about preceptor availability (that requiring only CNS preceptors could constrain placements) and recommended language that allows other advanced practice clinicians to precept under appropriate oversight. The draft regulatory sections address program administration, faculty qualifications, directors, clinical preceptors and curriculum; staff noted that the draft includes a consumer notice adapted from NP regulations.

Advocacy and full practice authority: the California Association of Clinical Nurse Specialists (CACNS) representatives stressed advocacy for “full practice authority” for CNSs, arguing that expanded authority would improve access, reduce delays in care and enable CNSs to lead evidence‑based practice and system improvements. Elena Spetlove, CACNS president‑elect, said the association is building a speaker bureau and a preceptor network to support education and public visibility.

Next steps: staff said the draft regs will continue through BRN internal review (DCA legal, then Office of Administrative Law processes). The committee’s regulatory subcommittee will continue offline work to refine language and collect stakeholder input; any formal proposal would be posted for public comment when the board staff submit a rulemaking package.

Votes at a glance: The committee approved the minutes for the Aug. 15, 2024 meeting by roll call (see Vote record below).