Tell CMS: It is Dangerous to Equate Nurses with Physicians

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Dear AAPS Members and Friends,

The Center for Medicare and Medicaid Services (CMS) is continuing down a dangerous path of policies that deem practitioners who have far less rigorous training to somehow be equal to physicians.

It is critical that you take advantage of an opportunity to share your thoughts about this with the agency.

Comments are due by January 17 and they need to be sent in an email to [email protected] with the phrase “Scope of Practice” in the subject line.

For many email apps, clicking here will open a new message with the proper subject line, template comments, and email address filled in for you.  (If the link doesn’t work, please simply copy and paste the address, subject line, and sample text below into a new message.)

Please feel free to edit and customize the draft comments to your satisfaction before sending the email to CMS.  Add your name, city, and state to the bottom of the message.  De-identified examples you’ve encountered where patient safety has been compromised could also be helpful to add (without mentioning individual’s names or other identifiable details).

Here’s a draft comment to help you get started:


Dear Administrator Verma,

Deeming non-physicians to be essentially equal in training and experience to physicians amounts to a dangerous experiment on American patients. It is improper and unethical for the federal government to be making such decisions regarding the scope of practice of medical professionals.

Likewise it is irrational and counterproductive to pay a minimally trained person the same as a highly trained, experienced person. If the reimbursement is the same for poor quality as for good quality, but the poor quality costs less to provide, the entities that degrade quality have a competitive economic advantage. Medicare’s existing price controls are already impeding patient access to high quality care and should not be exacerbated by additional flawed policies that further disregard important differences between practitioners. 

The bottom line is that patients’ lives are at risk. The federal government should follow a policy of “first do no harm.” It violates this principle to impose top-down edicts declaring that non-physicians are qualified to practice medicine. I urge the federal government to reject such policies.


Thank you for speaking out. Your voice makes a difference.