should be eligible for the same enhanced reimbursement and support provided by the government to Federally Qualified Health Centers.

Undertake Other Available Measures to Improve APNs’ Practice Context

While I candidly acknowledge that I am not aware of all of the many authorization, payment, or even survey provisions contained in the hundreds of state and federal regulatory measures affecting APNs—and I am not sure that anyone could be—I do know that there are many examples of APNs’ differential treatment or total absence. While policy makers and other public advocates move forward with efforts to remove many of the large-scale impediments resulting from the dynamics previously discussed, there are immediate steps that can be taken improve the practice context for APNs. Several specific examples follow:

  • The CMS should ensure that APN practices, including Nurse-Managed Health Centers, are eligible to receive subsidies under the ARRA of 2009/stimulus funds for adoption of the Electronic Health Records systems currently being developed by the Health Information Technology Policy Committee, or any other HIT initiatives.

  • The Office of Personnel Management should condition any insurer’s participation in the Federal Employees Health Benefits Program upon verification that APNs’ services (consistent with their full authority under state law) are directly accessible by members and are covered and paid for on the same basis as physicians.

  • Any federally sponsored initiative to promote patient-centered, coordinated primary care should incorporate the Institute of Medicine’s definition of primary care, which includes “the provision of integrated, accessible health care services by clinicians who are accountable … [emphasis added]” (IOM, 2001). Consistent with this, legislation and implementing rules should assure that any federal pilot or demonstration initiatives under Medicare or Medicaid promoting primary care (such as “health- or medical-homes”) include APN-led practices and Nurse-Managed Health Clinics as eligible participants. Furthermore, CMS should encourage or require any accrediting organization (such as the National Committee on Quality Assurance) whose assessments and recognition are relied upon in any way for basic or enhanced reimbursement, to include APN-led practices in their health/medical home standards and processes.

  • In Medicare legislation and CMS regulations, the terms “physician” and “physician services” should be defined to include APNs’ services when those services are within the APNs’ scope of practice as defined by state law.

  • Medicare legislation and implementing regulations should authorize



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