October 10, 2006
The Honorable Mark B. McClellan, MD, PhD
Centers for Medicare and Medicaid Services
U.S. Department of Health and Human Services
Room 445-G, Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, DC 20001
Re: Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule for Calendar Year 2007 and Other Changes to Payment Under Part B - CMS-1321-P
Dear Administrator McClellan:
On behalf of our organizations and the hundreds of thousands of nurses we represent, we are writing to respectfully request that you and your staff work this year to modify the Medicare payment database so it can capture nurse practitioner specialty-specific data beginning in 2007. Taking this important action will help ensure that the nations nurse practitioners can participate in future Centers for Medicare and Medicaid Services (CMS) demonstration and pay-for-performance/value-based purchasing programs.
As you know, nurse practitioners are registered nurses who are prepared through advanced education and clinical training to provide a wide range of preventive and acute health care services to individuals of all ages. Studies consistently have found that nurse practitioners provide high quality, cost-effective care. Moreover, nurse practitioners often are sole providers of care in underserved and rural communities. With the nation facing the dual challenges of a growing physician shortage and the aging of the Baby Boom generation, nurse practitioners will play an even more important role in providing quality care to Medicare beneficiaries in the years to come.
It is our understanding that the Medicare database currently does not permit the collection of nurse practitioner specialty-specific data. This current limitation unfairly excludes nurse practitioners from participating in certain demonstration projects and will preclude your agency from being able to evaluate nurse practitioners with respect to any pay-for-performance/value-based purchasing programs. We understand that since the Medicare payment database currently captures physician specialty-specific data that the inclusion of nurse practitioner specialty-specific data is feasible. We feel strongly that it is essential to address this differential in data collection and believe that the collection of this additional information will prove extremely useful to CMS and the Medicare program.
We appreciate your attention to our request and stand ready to work with you and your staff on this and other efforts to ensure that nurse practitioners are integrated fully into CMSs data collection efforts, pay-for-performance/value-based purchasing programs, and other related endeavors. If we can be of any assistance or should you have any questions, please do not hesitate to contact any of our organizations.
Academy of Medical-Surgical Nurses
American Academy of Ambulatory Care Nursing
American Academy of Nurse Practitioners
American Association of Nurse Anesthetists
American Association of Occupational Health Nurses, Inc.
American College of Nurse Practitioners
American Nephrology Nurses Association
American Organization of Nurse Executives
Association of Faculties of Pediatric Nurse Practitioners
Emergency Nurses Association
Oncology Nursing Society
Public Health Nursing Section of the American Public Health Association
Society for Urologic Nurses and Associates
Society of Gastroenterology Nurses and Associates
Wound, Ostomy and Continence Nurses Society