CMS Called for Scope of Practice Feedback in Response to President Trump’s Medicare Executive Order

Last Updated: Jan 18, 2020

team-doctorsThe Centers for Medicare and Medicaid Services (CMS) recently requested feedback on scope of practice in connection to a Medicare executive order issued by President Trump on Oct. 3, 2019. The comment deadline was Jan. 17, 2020.

Section 5 of the order suggested an expansion of the scope of practice for certified registered nurse practitioners (CRNPs) and physician assistants (PAs) by eliminating supervision requirements. In addition, it says services for PAs and CRNPs should be “appropriately reimbursed in accordance with work performance rather than the clinician’s occupation.”

PAMED was one of the 102 state medical societies that signed on to this letter the American Medical Association sent to U.S. Health and Human Services Secretary Alex Azar in October 2019. The letter raised concerns about the language in the executive order related to scope of practice.

When the 2020 Medicare Physician Fee Schedule (MPFS) was released in November 2019, CMS acknowledged the response it received from stakeholders on scope of practice expansion. As a result of this feedback, the 2020 MPFS defers to existing state law and scope of practice rules related to physician supervision. We applaud CMS for listening to physician concerns and acting accordingly.

However, PAMED continues to have concerns regarding the executive order’s suggestion that clinicians be reimbursed based on time rather than a clinician’s occupation. We shared our feedback on Section 5 via a comment letter sent to CMS on Jan. 16, 2019.

“While all health care professionals play a critical role in providing care to patients, their skillsets are not interchangeable with that of a fully trained physician,” wrote PAMED President Lawrence John, MD in our letter. “The scope of practice and reimbursement of health care professionals should be commensurate with their level of education and training, not based on anything else. Patients – and in this case Medicare patients – deserve nothing less.”

Read the letter.

Learn more about PAMED’s advocacy initiatives on scope of practice at


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  1. Donald Durbeck | Jan 02, 2020

    How can one ever expect a Nurse Practitioner or a PA to perform at the same level as an MD or DO?  They simply do not have the training necessary to do this.



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