APSHO Comments: Centers for Medicare & Medicaid Services

OUTCOME

Download template comment letter

Dear APSHO Members,

We would like to ask you to send your comments to CMS about the proposed rule for the 2021 calendar year Medicare Physician Fee Schedule released on August 3, 2020 (CMS-174-P). The proposed rule allows CMS coverage of diagnostic tests when supervised by an advanced practitioner. It further enables pharmacists to provide services “incident to” physician or NPP services, such as medication management, when operating under the appropriate level of supervision and consistent with state law. Both of these previous restrictions were lifted during COVID-19 pandemic pursuant to the Public Health Emergency. 

These proposed changes are important to all advanced practitioners as we pursue care of the oncology patient at the highest level of our scope of practice. We want to encourage CMS to continue to evaluate ways to remove unnecessary and outdated practice barriers for APs that are not founded on legitimate health and safety concerns. 

The CMS comment period will end at 5 pm on October 5. Please submit your comments before then to https://beta.regulations.gov/commenton/CMS-2020-0088-1604. APSHO has provided a template for you to personalize and add additional comments if desired (Download Template). A copy of the comments APSHO made regarding this matter may be found here.

Thank you so much for all you do for APSHO, your fellow advanced practitioners, and your patients! 

Sincerely,

Wendy Vogel, MSN, FNP, AOCNP^®
Executive Director, APSHO
On behalf of the APSHO Board of Directors