WHA offered several recommendations in a comment letter to CMS Jan. 17 to address Medicare regulations that limit advanced practice clinicians from practicing at the top of their licenses in hospitals, adding to physicians’ administrative burden. WHA’s comment letter responded to a CMS solicitation for assistance in developing future reforms to the Medicare program, including removing burdensome requirements impacting physician assistant and advanced practice registered nursing practice.
“Regulatory burden creates additional cost on the health care system and limits the productivity of health care providers,” WHA’s letter to CMS Administrator Seema Verma said. “Wisconsin, like other states, has workforce challenges that impact our members’ ability to meet the demands for care of our citizens, and regulatory burden directly impacts the amount of clinical care that physicians and non-physician professionals can provide in one day.”
To address regulatory burden on physicians, advanced practice clinicians and team-based care delivery, WHA’s comment letter recommended several clarifications to CMS’s Hospital and Critical Access Hospital Conditions of Participation that would better recognize advanced practice clinicians’ scope of practice and avoid unnecessary physician co-signatures.
WHA’s proposals include clarification and alignment with other CMS policies regarding physician co-signature requirements for hospital admissions, certifications of care, history and physical performance, and discharge orders and summaries.
WHA’s recommendations to CMS were drawn from presentations at WHA’s Advanced Practice Clinician Conference held in September 2018 that highlighted problematic federal regulations limiting the ability of advanced practice clinicians from practicing to their full scope of practice in hospital settings.
If you have questions about CMS’s solicitation or WHA’s comment letter, contact WHA General Counsel Matthew Stanford or WHA Vice President Workforce & Clinical Practice Ann Zenk.