All federal agencies (CMS, NCHS, HRSA, etc.) should be charged with ensuring that any coding, assessment or benchmark schema used in any federal health care program (or state program receiving federal funds) for payment, performance, accreditation, or forecasting purposes are inclusive and fairly representative of the kinds of providers and practices affected by those schema. A partial list of such metrics would include the Medical Expenditure Panel Survey, HEDIS, CAHPS, CPT codes, performance measures and quality indicator data sets, Joint Commission and National Quality Forum standards, and benchmark tools for federally sponsored pilot and demonstration projects and the like.
The Federal Trade Commission (FTC) should be charged with actively monitoring proposed state laws and regulations specifically applicable to retail or convenient care clinics (or other innovative delivery mechanisms utilizing APNs) to ensure that impermissible anti-competitive measures are not enacted. The need for such monitoring is confirmed by the recent FTC29 evaluations of proposals in Massachusetts and Illinois and Kentucky, which revealed that several such provisions (including limitations on advertising, differential cost-sharing, more stringent physician supervision requirements, restrictions on clinic locations and physical configurations or proximity to other commercial ventures, and limitations on the scope of professional services that can be provided which do not apply to the same credentialed professionals in comparable limited care settings) could be considered anticompetitive.
Curriculum The Department of Education should emphasize interdisciplinary curricular opportunities in the criteria used by the National Advisory Committee on Institutional Quality and Integrity in granting continued recognition of nationally recognized accrediting agencies for health care education.
Graduate-level education for APNs Federal funding for graduate-level, APN education (and educational loan-repayment subsidies) should be expanded. Since the time and cost required for completing APN educational and training require-
Letter from FTC Staff to Elain Nekritz, Illinois Legislature (May 29, 2008), available at http://www.ftc.gov/os/2008/06/V080013letter.pdf; Letter from FTC Staff to Massachusetts Department of Health (September 27, 2007), available at http://www.ftc.gov/os/2007/10/v070015massclinic.pdf. Letter from FTC Staff to Kentucky Cabinet for Health and Family Services (January 28, 2010), available at http://www.ftc.gov/os/2010/02/100202kycomment.pdf.