U.S. Department
of Justice
HCW-00030 Oklahoma City University - Kramer School Of Nursing (Kramer, Stephanie)
Submission Number: 00030
Received:4/5/2015 8:59:21 PM
Commenter: StephanieKramer
Organization:Oklahoma City University - Kramer School of Nursing
State:Oklahoma
Agency: Federal Trade Commission
Initiative:FTC, DOJ to Host Second Public Workshop on Examining U.S. Health Care Competition; Project No. P13-1207
Attachments: No Attachments
Submission Text
To all in the FTC and DOJ anti-trust departments- I am sure you have been inundated with commentary about Nurse Practitioners' practice authority in states with collaborative agreements. I live in Oklahoma, which is a collaborative practice state. We have been lobbying for practice that does not require a collaborative agreement, in accordance with the IOM 2010 report and the FTC report FTC140307aprnpolicy. I am currently an APRN student working with preceptors in various office settings. I have seen many problems these settings. With the recent change in the schedule of Norco from a III to a schedule II drug, this has severely limited the ability of any non-metropolitan APRN to manage a patient's pain appropriately. I know this may not be in the purview of the FTC and DOJ but it does affect patient care all over the nation. With this change, it has created a fiscal, emotional and logistical nightmare for patients and APRNs. If APRNs are allowed to practice to the full scope of education and licensure, the schedule of a drug would not matter for it would fall under the scope of practice. The anti-trust issue is a "clear and present danger" in all states that do not allow full scope of practice for APRN's. You know there is a mountain of evidence showing that APRNs practice safely and no evidence that physician involvement mitigates any patient safety issues. An APRN recently received a letter from her collaborating physician that stated since he had to sign home health orders and hospice orders, that made him legally liable for that patient, and he was unwilling to take on that responsibility. He has advised her that he would not be liable for any new patients. For any APRN, this would significantly limit the practice of that APRN and severely limit the ability of home health and hospice patients to obtain timely care. The liability is real and understandable. - This limitation is unnecessary, according to the evidence the FTC and the IOM have reviewed. - This limitations affects the ability of the APRN to provide quality health care in the market place. -This limitation puts a monopoly on patients that physicians are not prepared to manage. I would encourage the FTC to review how many physicians have dropped their Medicare and Medicaid contracts, two of the most vulnerable populations. I would also encourage the FTC and DOJ to review the consequences of the declining physician collaboration with APRNs in those 30 states and any other US territories affected by this lack of collaboration. It is irrelevant about their reasoning for their lack of collaboration for safety or liability reasons. The consequences are relevant.
Received:4/5/2015 8:59:21 PM
Commenter: StephanieKramer
Organization:Oklahoma City University - Kramer School of Nursing
State:Oklahoma
Agency: Federal Trade Commission
Initiative:FTC, DOJ to Host Second Public Workshop on Examining U.S. Health Care Competition; Project No. P13-1207
Attachments: No Attachments
Submission Text
To all in the FTC and DOJ anti-trust departments- I am sure you have been inundated with commentary about Nurse Practitioners' practice authority in states with collaborative agreements. I live in Oklahoma, which is a collaborative practice state. We have been lobbying for practice that does not require a collaborative agreement, in accordance with the IOM 2010 report and the FTC report FTC140307aprnpolicy. I am currently an APRN student working with preceptors in various office settings. I have seen many problems these settings. With the recent change in the schedule of Norco from a III to a schedule II drug, this has severely limited the ability of any non-metropolitan APRN to manage a patient's pain appropriately. I know this may not be in the purview of the FTC and DOJ but it does affect patient care all over the nation. With this change, it has created a fiscal, emotional and logistical nightmare for patients and APRNs. If APRNs are allowed to practice to the full scope of education and licensure, the schedule of a drug would not matter for it would fall under the scope of practice. The anti-trust issue is a "clear and present danger" in all states that do not allow full scope of practice for APRN's. You know there is a mountain of evidence showing that APRNs practice safely and no evidence that physician involvement mitigates any patient safety issues. An APRN recently received a letter from her collaborating physician that stated since he had to sign home health orders and hospice orders, that made him legally liable for that patient, and he was unwilling to take on that responsibility. He has advised her that he would not be liable for any new patients. For any APRN, this would significantly limit the practice of that APRN and severely limit the ability of home health and hospice patients to obtain timely care. The liability is real and understandable. - This limitation is unnecessary, according to the evidence the FTC and the IOM have reviewed. - This limitations affects the ability of the APRN to provide quality health care in the market place. -This limitation puts a monopoly on patients that physicians are not prepared to manage. I would encourage the FTC to review how many physicians have dropped their Medicare and Medicaid contracts, two of the most vulnerable populations. I would also encourage the FTC and DOJ to review the consequences of the declining physician collaboration with APRNs in those 30 states and any other US territories affected by this lack of collaboration. It is irrelevant about their reasoning for their lack of collaboration for safety or liability reasons. The consequences are relevant.
Updated April 7, 2016