• distributing the model to

    • state and federal entities responsible for any facet of regulating health providers’ practice or payment for services, and

    • private entities that utilize or pay for providers’ services (such as commercial insurers and health care facilities), or which establish or review standards for institutional or organizational accreditation.

This strategy would promote wider awareness of both the problems of the current system and the existence of achievable, preferred practices.

Incentivize the States to Adopt the Preferred Framework

Raise awareness and promote rational analysis Pursuant to existing (or, if necessary, supplemental) statutory authority for annual state reports and assessments of Medicaid and SCHIP, the Secretary of HHS and/or the Administrator of CMS could require the Governor and/or Director of Medicaid/SCHIP of each state to submit an annual report that:

  • specifies how any of their state’s health care provider practice acts and regulations impose restrictions not included in the preferred model framework, and

  • documents the justifications for these continued restrictions.

A compilation of these reports could be posted on the HHS and CMS and other appropriate websites and could be distributed to associations such as the National Council of State Legislatures and the National Governors’ Association, as well as to public advocacy groups.


Create fiscal incentives A final step in this progression would move from increasing awareness of to incentivizing the adoption of the preferred framework. The Medicaid federal match formula could be increased by 0.5 percent for those states that revise their laws to be consistent with the preferred framework, or (perhaps more equitably for those states that have already reformed their laws) the federal match for nonconforming states could be decreased by 0.5 percent.

Ensure That APNs Are Visible, and That Their Roles Are Taken into Account

To ensure that APNs and nursing in general are “present and accounted for” when counting matters, at least two significant actions should be taken.

  • The National Center for Health Statistics should confirm that all its National Health Surveys and resulting statistical and series reports include information on the full range of APNs’ practices and settings.



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