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Federal Trade Commission staff submitted written comments to Missouri State Representative Jeanne Kirkton in response to a request for comments on legislative proposals that would remove or change requirements for “collaborative practice arrangements” between Missouri physicians and Advanced Practice Registered Nurses (APRNs).

According to the comment by staff of the FTC’s Office of Policy Planning, Bureau of Competition, and Bureau of Economics, Missouri House Bills 1481 and 1491 would curtail costly barriers to competition – barriers that may “deter procompetitive innovation in health care delivery, to the ultimate detriment of Missouri health care consumers, as well as both public and private third-party payors.”

As stated in the comment, HB 1491 would, in part, allow APRNs to assess and diagnose patients, and order diagnostic and therapeutic tests and procedures, without a collaborative practice arrangement with a particular physician, as is now required in Missouri. HB1481 would allow physicians and APRNs to collaborate electronically, replacing current law that requires their offices to be physically nearby.

The staff comment refers to an FTC staff policy paper, issued in March, which analyzes the competitive implications of various types of APRN regulations, including the mandatory collaborative practice arrangements now required under Missouri law. According to the policy paper, these types of rigid statutory requirements can “increase health care costs and prices,” needlessly constrain innovation in health care delivery,” and “exacerbate well-documented provider shortages.” The policy paper also cites research suggesting that these types of mandates do not appear necessary to promote coordination among health care providers or to assure that care is safe and effective.

The Commission vote to issue the staff Policy Paper was 5-0. (FTC File No. V140009; the staff contact is Daniel J. Gilman, Office of Policy Planning, 202-326-3136).

The FTC’s Office of Policy Planning works with the Commission and its staff to develop long-range competition and consumer policy initiatives, consistent with the FTC’s unique mission to conduct research and engage in advocacy on issues that affect competition, consumers, and the U.S. economy. The Office of Policy Planning submits advocacy filings; conducts research and studies; organizes public workshops; issues reports; and advises staff on cases raising new or complex policy and legal issues. To reach the Office of Policy Planning, send an e-mail to Like the FTC on Facebook, follow us on Twitter, read our blogs, and subscribe to press releases for the latest FTC news and resources.

Contact Information

Frank Dorman
Office of Public Affairs