ASM Asks VA for Clarification on Proposed Advance Practice RN Duty Changes

July 27, 2016

Director, Regulations Management (02REG)
Department of Veterans Affairs
810 Vermont Avenue NW, Room 1068
Washington, DC 20420

To Whom It May Concern:

The American Society for Microbiology (ASM) welcomes the opportunity to comment on proposed changes to the Department of Veterans Affairs (VA) proposal to amend its medical regulations to permit full practice authority of all VA advanced practice registered nurses (APRNs) when they are acting within the scope of their VA employment. This proposed rule, “RIN 2900-AP44-Advanced Practice Registered Nurses” appeared in the May 25, 2016 issue of the Federal Register.

Many ASM members have primary involvement in clinical laboratory medicine including individuals directing clinical microbiology, immunology and molecular diagnostic laboratories, individuals licensed or accredited to perform, supervise, and interpret such testing, industry representatives developing laboratory products for use, and researchers involved in development and evaluation of new technologies. Therefore, the ASM has significant interest in the training and certification of those performing diagnostic laboratory tests.  The proposed regulation states:

In proposed § 17.415(d)(1)(i), a CNP would have full practice authority to provide the following services:

examinations and other health assessment and screening activities; diagnose, treat, and manage patients with acute and chronic illnesses and diseases; order, perform, supervise, and interpret laboratory and imaging studies; prescribe medication and durable medical equipment and; make appropriate referrals for patients and families; and aid in health promotion, disease prevention, health education, and counseling as well as the diagnosis and management of acute and chronic diseases.

Are these laboratory studies limited to point of care testing (CLIA waived) testing, or does this proposal extend to clinical laboratories as well?  Does the VA have a scale of complexity, similar to the CLIA complexity scale?  If so, which level types of tests are you considering based on the waived, moderate or high complexity model?

We look forward to clarification at your earliest convenience. 

Sincerely,

Susan Sharp, Ph.D.
President, American Society for Microbiology

Stefano Bertuzzi, Ph.D., M.P.H.
CEO, American Society for Microbiology

Ronald M. Atlas, Ph.D.
Chair, ASM Public and Scientific Affairs Board

Robert Jerris, Ph.D., D(ABMM)
Chair, Professional Affairs Committee