Comment Letter

Neurosurgery Urges VA to Respect State Scope of Practice Laws

  • Quality Improvement and Patient Safety

The Honorable Denis McDonough
U.S. Department of Veterans Affairs
810 Vermont Avenue NW
Washington, DC 20420

Dear Secretary McDonough:

The undersigned medical societies are writing to convey our ongoing concerns with the Department of Veterans Affairs (VA) effort to develop National Standards of Practice (NSP) through the Federal Supremacy Project. We urge the VA to address flaws in the NSP development process, including halting efforts to supersede well-established state law.

Our previous letters highlighted our concerns that the VA’s efforts to develop NSPs for 51 health care occupations preempts state scope of practice laws, potentially allowing non-physicians to perform procedures that are outside the scope of their knowledge, training, and state-based licensure and, importantly, making it virtually impossible for state boards to oversee medical care at VA facilities in their states. While these concerns remain front and center in our opposition to the Federal Supremacy Project, equally problematic is the differential standards that will inevitably result between the NSPs and state licensure and scope of practice laws. Veterans would be exposed to a different and lower standard of practice than non-Veterans.

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