Organizational Responses

• Comments on American Nursing Association’s work in seeking Ethical Environments and Patient and Personal Safety
  March 2020 letter offering feedback from the APNA Council for Safe Environments.
• Comments on Current Medicare Regulations that Limit Providers’ Scopes of Practice
  January 2020 letter offering feedback regarding CMS’ continuation of its work under section 5 of Executive Order #13890 on Protecting and Improving Medicare for Our Nation’s Seniors.
• Comments on CCNE’s Proposed Standards for Accreditation of Nurse Practitioner Residency/Fellowship Programs
  January 2020 letter providing comments on standards proposed by the Commission on Collegiate Nursing Education.
• Response to the Arrest and Treatment of Alex Wubbels
  September 2017 letter of support to the American Nurses Association and the Utah Nurses Association for their position on the manner in which a nurse was treated while fulfilling the duties of her position.
• Comments on the National Patient Safety Goal Related to Suicide Field Review for Hospitals
  May 2017 letter to the Joint Commission Division of Healthcare Quality Evaluation in support of proposed revisions to the National Patient Safety Goal Related to Suicide for hospitals.
• Response to VA Rule Regarding APRN Practice Authority
  January 2017 letter to the Department of Veterans Affairs on the recent rule regarding APRN practice authority and encouraging further action.
• Introductory Letter to the Presidential Transition Team
  December 2016 letter from the Nursing Community explaining their priorities to the Presidential Transition Team, including access, affordability, and quality of healthcare.
• CARA Act Request for Public Comment on New Buprenorphine Training Requirements
  November 2016 letter in response to the Comprehensive Addiction Recovery Act (CARA) of 2016 training requirements for nurse practitioners and physician assistants.
• Veteran’s Health Administration Proposed Rule to Grant Full Practice Authority to APRNs
  June 2016 letter supporting the proposed rule while emphasizing the shared scope of practice of psychiatric-mental health Nurse Practitioners and Clinical Nurse Specialists.
• SAMHSA Proposed Rule: Medication Assisted Treatment for Opioid Use DisordersMay 2016 comments urging SAMHSA to expand access to buprenorphine through legislative changes that give advance practices nurses (NPs and CNSs) with already recognized prescriptive authority authorization to prescribe buprenorphine.
• FDA Proposed Reclassification of ECT Devices
  A March 2016 letter which draws from member expertise and an APNA position paper to urge the Food and Drug Administration to reclassify electroconvulsive devices.
• National Institute of Nursing Research Strategic Plan
  A March 2016 letter which integrates feedback from the APNA Research Council and APNA members on the NINR’s draft strategic plan.
• National Council of State Boards of Nursing (NCSBN) Proposed APRN Compact Model Legislation
  A February 2014 letter which synthesizes comments received from APNA members and councils on the new proposed APRN Compact Model Legislation from NCSBN.
• American Nurses Association Position Paper on Seclusion and Restraint
  This organizational response, sent to the American Nurses Association on November 8, 2011, incorporates feedback from APNA members, councils, and the Board of Directors on ANA’s position paper regarding seclusion and restraint.
• Centers for Medicare & Medicaid Services’ (CMS) proposed rule on Conditions of Participation (CoP) for Community Mental Health Centers (CMHCs)
  This organizational response, submitted to CMS in August 2011, incorporates feedback from APNA’s members, councils, and Board of Directors. APNA notified its councils and membership of this proposed rule in early July 2011 and requested feedback. The councils each conducted a critical review of the proposed rule and council chairs then provided summaries of their discussions to the Board of Directors. Individual APNA members were urged to comment directly to CMS in addition to sending a copy of their response to APNA. All of these comments were reviewed and considered by the Board of Directors as they composed the organization’s formal response.
• Inpatient Psychiatric Facility Quality Reporting Measures from CMS and the National Committee for Quality Assurance (NCQA)
  In August 2011, after soliciting feedback from APNA members, councils, and the Board of Directors, APNA submitted these comments regarding the inpatient psychiatric facility quality reporting measures. APNA’s comments represent the Board of Directors’ review and synthesis of all of the responses recieved from our councils and membership. Members were also invited to submit their individual comments directly via NCQA’s Public Comments website.