August 12, 2011

Donald M. Berwick, MD
Administrator,
Medicare & Medicaid Services
Department of Health and Human Services

Dear Dr. Berwick:

On behalf of the American Psychiatric Nurses Association, I am pleased to respond to your request for comments on the proposed rule for the Medicare Program Conditions of Participation (CoPs) for Community Mental Health Centers.

I have attached a complete copy of our comments but wish to call to your attention two areas about which we wish to express significant concern. The first is that psychiatric-mental health advanced practice nurses are omitted from the Interdisciplinary Team list. Excluding advanced practice registered nurses creates limited access for patients with mental illness or substance abuse disorders. Furthermore it raises a quality of care issue in that any physician (without any psychiatric training) can perform a psychiatric evaluation but a specialty-trained PMH NP/CNS would not be allowed.

The second issue deals with the use of the term “physician led” rather than “provider led”. This request in change in language is recommended for the entire document. Even if "physician" is required by current federal and state law, the change to the register from "physician" to "provider" would continue to follow the law but allow for future changes in the law to include other providers without having to change the register language. More importantly it provides flexibility to those centers who are not able to recruit physicians with training and background in psychiatry.

The American Psychiatric Nurses Association (APNA) was founded in 1986 and is the largest professional membership organization committed to the specialty practice of psychiatric-mental health nursing (PMHN). Initiatives include wellness promotion, prevention of mental health problems and the care and treatment of persons with psychiatric disorders across the lifespan. APNA is the only PMH nursing organization whose membership is inclusive of all PMHN at basic (RN) and advanced practice levels (NP and CNS). APNA’s more than 7,500 members come from every state and include international members. APNA also has a panel of mental health consumers that offer advice to the governing board in formulating policy statements.

Sincerely,

Carole Farley-Toombs
President
American Psychiatric Nurses Association

Enclosure

1555 Wilson Blvd., Suite 530, Arlington, VA 22209           Main: 703-243-2443           Fax: 703-243-3390          www.apna.org



APNA Organizational Response
Download a PDF of this letter and APNA's Organizational Response