Dr. Woodbury comments upon AP-44: Veterans Administration

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Dear friends, neighbors, colleagues, medical students, patients,

The Veterans Administration is in the process of receiving final comments from the public on a significant new regulation, called “AP44- Proposed Rule - Advanced Practice Registered Nurses.”

AP-44 defines “Advanced Practice Registered Nurses” as 1.) Certified Nurse Practitioners; 2.) Certified Registered Nurse Anesthetists(CRNAs); 3.)Clinical Nurse Specialists, and 4.) Certified Nurse Midwives. AP-44 would remove or supplant state laws that require APRNs to operate under the supervision of a physician. APRNs would be allowed to operate in their capacity of VA employment (in the nation’s 152 Veterans Administration Medical Centers or the 1400 Veterans Outpatient Centers) under a new VA rule by which they would no longer operate under the supervision of a physician or medical doctor in preparing prescriptions, managing airway access, in the diagnosis, management, or treatment of acute and chronic illnesses, and in ordering, performing, supervising, or interpreting laboratory and imaging studies.

Even if a state (such as Tennessee) requires that advanced practice registered nurses be under the supervision of a physician in making a diagnosis or ordering prescriptions, AP-44 would supplant state laws for Veterans Administration facilities, except for prescription of controlled substances (narcotics).
For safety reasons, this proposed change in Veterans Administration rules requiring physician oversight is most concerning. Nurse practitioners should continue to operate under the supervision of physicians, for the safety of veterans. Physicians (medical doctors or osteopathic doctors—MDs or ODs) in Tennessee have spent a minimum of 6 years after college in training before being granted by our state licensure the ability to prescribe drugs, four years of which are in direct patient care. The depth of training and experience of a physician allows for earlier detection of and management of clinical problems. It’s a safety issue.

Comments must be received by VA on or before July 25, 2016. Comments may be submitted either on-line, through, or in writing, to Director, Regulations Management (02REG), Department of Veterans Affairs, 810 Vermont Avenue NW., Room 1068, Washington, DC 20420; by fax to (202) 273-9026. Comments should indicate that they are submitted in response to “RIN 2900-AP44-Advanced Practice Registered Nurses.”
To comment on the web site, click
and you can click on the "Comments!" tab to the right top of the screen, to enable you a chance to comment on this proposed regulation.

For questions/comments to myself, or to unsubscribe:

George Woodbury Jr. M.D. (07/20/2016)

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