Announcement of Public Workshop, "Examining Health Care Competition" ("Health Care Workshop") Project No. P13-1207 #00112

Submission Number:
Whitney Blanco
New York
Initiative Name:
Announcement of Public Workshop, "Examining Health Care Competition" ("Health Care Workshop") Project No. P13-1207
"I am a student at Columbia University. However, this comment to the Federal Trade Commission reflects my own personal opinions. This is not representative of the views of Columbia University or the Trustees of Columbia University." The ACA is an intentional and organized shift from volume-based healthcare delivery, which was driven by a fee-for-service framework, to a value-based healthcare delivery, which is characterized by a managed care and continuity-of-care framework. The managed care approach has several aspects that are imperative to its successful execution. A key component is the federal regulation of nurse practitioners (NP or NPs). NPs have proven to be an incredible asset to hospitals across the nation; however, the lack of financial payment and structural recognition does not reflect their added value to healthcare. The Center for Medicaid and Medicare Services (CMS) is aware of the unnecessary barriers many nurse practitioners face, and they are making strides towards addressing the issue. Nevertheless, CMS must be more aggressive with a federal regulation that can and will be nationally adopted by Critical Access Hospitals (CAH). Regulation must include a standardized scope of practice for advanced practice registered nurses and a payment scheme that is in compliance to Medicare and Medicaid reimbursement. Immediate Policy Options: 1.Federally regulate the degree of independence and supervision for APRNs within hospitals and independent practices in terms of CPT and DRG codes, practice-scope guidelines, and measurable outcomes. 2.Provide financial incentives to hospitals and independent practices to define the scope of practice for physicians, nurse practitioners and administrators. Examples of the degree of scope include admitting privileges, [eligibility] for hospital clinical privileges, and hospital medical staff membership. Scope of practice for APRNs should not vary from state to state. 3.Continue to fund and conduct research to scientifically prove which regulations produce the greatest results within the medical field. Standardize the balance of shared financial risk between payers and providers. The standardization should be used as cost-sharing guidelines for payers and providers. The guidelines should follow Delisle's guidelines in Big Things Come in Bundled Packages: The "Conditions of Participation" developed by CMS should be changed to require all hospitals to adopt the same definition and scope of practice for nurse practitioners. (Conway 1) This would increase competition among talent for nurse practitioners, as well as assess consistent monetary value to their provided services. Non-compliance to the terms can result in ineligibility for Medicare and Medicaid reimbursement. This strict guideline will require all hospitals that admit patients to adhere to the guidelines. Although this recommendation limits hospital and state autonomy, it also provides a platform for cost-measurement mechanisms and competition among talent and expertise. Clear and concise regulation will have to include all stakeholders. Coordination between physicians, nurses and health administrators is of the utmost importance. As we develop and assign codes that reflect NPs, consideration for existing codes must not be forgotten. Selecting the appropriate DRG coding will allow for the greatest overall cost savings, as well as maximize efficiency. Lastly, the lack of regulation upon hospitals must be coupled with greater regulation in nursing education. The greatest argument against NP scope and practice regulation is rooted in the multiple types of education a person can receive to become a nurse. Standardization upon the entrance into a profession requires greater regulation upon the entrance of education of the profession. This multiple-layered answer to federally regulate NP scope will require stakeholders from not only from the medical field, but from the education field as well.