Re: RIN 2900–AP44-Advanced Practice Registered Nurses; Proposed Rule (May 25, 2016)
The undersigned physician organizations representing national specialty and state medical societies are
writing to provide comments on the Veterans Health Administration’s (VHA) Advanced Practice
Registered Nurses (APRNs) Proposed Rule which, if finalized, would permit all VHA-employed APRNs to
practice without the clinical supervision of physicians and without regard to state law.
Nurses are an integral part of physician-led health care teams that deliver high quality care to patients.
They are often the first and last person to interact with a patient during an episode of care, and, in the case
of APRNs, they are well equipped to play advanced roles in the health care team. However, APRNs are no
substitute for physicians in diagnosing complex medical conditions, developing treatment plans that take
into account patients’ wishes and limited health care resources, and ensuring that the treatment plan is
followed by all members of the health care team. Nowhere is this more important than in the VHA, which
delivers highly complex medical care to disabled veterans, including those with traumatic brain injuries and
other serious medical and mental health issues. Our nation’s veterans deserve high quality health care that
is overseen by physicians. For the reasons below, the undersigned organizations strongly oppose the
Proposed Rule and urge the VHA to consider policy alternatives that prioritize team-based care
rather than independent nursing practice.
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