Major Wins for APRNs and CRNAs in the Latest CMS Physician Fee Schedule

AACN, along with our coalition partners representing nursing, medicine, and the other health professions, have worked to improve policies outlined in the Centers for Medicare and Medicaid Services' (CMS) proposed rule, CY 2020 Revisions to Payment Policies under the Medicare Physician Fee Schedule. AACN is pleased to see that the final rule reduces mandatory and duplicative medical record evaluation and management (E/M) documentation requirements, which resulted in two major wins for advanced practice registered nurses (APRNs) and nursing students.

Special thanks go to Dr. Ann Cary and her colleagues on NACNEP for their advocacy to revise the CMS policies. Read the letter from the National Advisory Council on Nursing Education and Practice (NACNEP) supporting changes to CMS' documentation requirements.

Specifically, the final rule includes AACN's recommendation to enable APRNs and physician assistants who furnish and bill for their professional services to review and verify, rather than redocument, information included in the medical record by physicians, residents, nurses, students, or other members of the healthcare team. This is a monumental step in reducing burden and eliminating disparities in clinical training opportunities.

AACN's second major successful recommendation to the rule pointed out that the proposed changes to E/M documentation only included three out of the four APRNs, omitting certified registered nurse anesthetists (CRNAs) who regularly complete comprehensive E/M documentation for patients. CMS is modifying the final rule to explicitly name Nurse Practitioner, Clinical Nurse Specialist, Certified Nurse Midwife, and CRNA students as APRN students and is also amending the regulation to include CRNAs as a category of APRNs.

AACN applauds the final rule on medical record documentation which relieves burdensome E/M documentation requirements for all four APRNs and advances the clinical learning experience for students. AACN will continue to support CMS initiatives that reduce unnecessary regulatory burdens currently impeding access to quality healthcare delivery for our nation's patients.

Read CMS Final Rule: See section II.J. Review and Verification of Medical Record Documentation.