MAG, AMA & others weigh in on CMS scope proposals

The Medical Association of Georgia was one of about 100 physicians’ advocacy organizations that signed a letter that was sent to the Centers for Medicare & Medicaid Services (CMS) to respond to CMS’ request for feedback on President’s Executive Order #13890 (‘Protecting and Improving Medicare for Our Nation’s Seniors’), which “directs CMS to propose a number of reforms to the Medicare program, including ones that eliminate supervision and licensure requirements of the Medicare program that are more stringent than other applicable federal or state laws.”

The letter from the physicians’ advocacy organizations says that, “In reviewing [the CMS] recommendations to change Medicare regulations that would weaken or eliminate physician supervision of nonphysician professionals, we strongly urge the Administration to rely on fact-based resources, including a thorough review of the education and training of nonphysician health care professionals and the impact on the overall cost and quality of care. We also urge the Administration to carefully review the true impact of state scope of practice laws on access to care across the country.”

It also points out that, “There is a vast difference in the education and training of physicians and other health care professionals, including APRNs and PAs…well-proven pathways of education and training for physicians include medical school and residency, and years of caring for patients under the expert guidance of medical faculty. Physicians complete 10,000-16,000 hours of clinical education and training during their four years of medical school and three-to-seven years of residency training…nurse practitioners, the largest category of APRNs, must complete only 500-720 hours of clinical training after two-three years of graduate-level education. Physician assistant programs are two-years in length and require 2,000 hours of clinical care. Neither nurse practitioner nor PA programs include a residency requirement…physicians are required to pass a series of comprehensive examinations prior to licensure…nurse practitioners must [only] pass a single test consisting of 150-200 multiple choice questions…[and]  physician assistants must pass a single 300-question multiple choice exam.”

And the physicians’ groups “caution the Administration against positioning scope of practice as an administrative burden. Doing so obfuscates the very real administrative burdens facing physicians and other health care professionals every day, where every hour they spend providing clinical care to their patients requires two hours of administrative tasks.”

Finally, the letter stresses that, “While all health care professionals play a critical role in providing care to patients, their skillsets are not interchangeable with that of fully trained physicians. The scope of practice of health care professionals should be commensurate with their level of education and training, not based on politics.”

In its request for feedback, CMS said that the existing scope requirements are “burdensome” and “ultimately limit health care professionals, including physician assistants (PAs) and advanced practice registered nurses (APRNs), from practicing at the top of their professional license.”

CMS letter