ISASS Comments on Department of Veteran Affairs Proposal to Expand Scope of Services for Nonphysician Providers in VA Facilities

On June 24, 2020, ISASS and other organizations sent a comment letter to the Department of Veteran Affairs (VA) to the attention of Secretary Robert Wilke asking the VA to rescind an April memorandum expanding privileges for nonphysician providers such as nurse practitioners (NPs) and physician assistants (PAs) in regards to the 2020 Inpatient Rehabilitation Facility (IRF) Proposed Rule. The memorandum was released on April 21, 2020.

The organizations urged the secretary to amend the Directive 1899 as it relates to allowing non-physician healthcare professionals in 32 specialties to operate “within the full scope of their license, registration, or certification” and rescind the memorandum as it relates to encouraging all VA medical facilities to allow certified registered nurse anesthetists to practice without physician oversight during the national health emergency. The organizations are very concerned that Directive 1899 preempts state scope of practice laws. Directive 1899 memorializes U.S. VA policy, allowing VA health care professionals to practice across state lines, and establishes new policy allowing VA health care professionals to operate within the full scope of their license, registration, or certification. This combination would in effect circumvent state scope-of-practice laws for the 32 health care professionals defined in the directive. Such a far-reaching expansion is overly broad, unnecessary, and threatens the health and safety of patients within the VA system. As state scope-of-practice laws vary across these professions and across states, the letter urged the secretary to amend the directive to defer to state scope-of-practice laws.

To read the memorandum, click here: []

Read the comment letter here.

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