Dear Secretary Azar:
The undersigned organizations represent the hundreds of thousands of physicians who treat our
nation’s Medicare patients every day. We are committed to working with the Administration on
efforts to improve the program. We want to highlight our concerns, however, with a provision in
the October 3, 2019 Executive Order entitled, “Protecting and Improving Medicare for our
Nation’s Seniors.”
We are concerned with the broad yet vague language in section 5, particularly the language
related to the supervision and reimbursement of nonphysician professionals. We are highly
concerned this language requires the Secretary of Health and Human Services to propose a
regulation to eliminate or weaken current Medicare supervision requirements of nonphysician
professionals, a critical safeguard to ensure the health and safety of Medicare patients and the
cornerstone of the widely adopted team-based approach to health care. Scope of practice of
health care professionals should be based on standardized, adequate training and demonstrated
competence in patient care, not politics. While all health care professionals share an important
role in providing care to patients, their skillset is not interchangeable with that of a fully trained
physician.
The undersigned organizations have long supported physician-led health care teams, with each
member drawing on their specific strengths, working together, and sharing decisions and
information for the benefit of the patient. Just as teams do in business, government, sports, and
schools, health care teams require leadership. With seven or more years of postgraduate
education and more than 10,000 hours of clinical experience, physicians are uniquely qualified to
lead the health care team. Team-based care has a proven track record of success in improving the
quality of patient care, reducing costs, and allowing all health care professionals to spend more
time with their patients. Before imposing broad stroke changes to Medicare’s supervision
requirements and reimbursement policies, the undersigned organizations encourage the
Administration to carefully review and consider fact-based resources, including a thorough
review of the vast differences in education and training of nonphysician health care professionals
and the impact on the overall cost of care.
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