Comment Letters




  • AANA Recommends to CMS RFI that Medicare Should Amend Guidance to Clarify that CRNAs can Order and Refer Services if Allowed Under State Law, November 18, 2019
  • AANA Advises CMS that CRNAs Use a Multi-Model Pain Management Approach, Which May Reduce Patient Need for Opioids in Response to Opioid Addiction RFI, October 2, 2019
  • AANA and its Coalition Partners Recommend Incentivizing Non-Opioid Pain Management Approaches to Help Curb Opioid Epidemic, September 27, 2019
  • AANA Submits Comments on the CMS Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems Proposed Rule, September 25, 2019
  • AANA Strongly Supports CMS's Proposal in the Physician Fee Schedule Allowing CRNAs to Evaluate the Risk of Anesthesia in ASCs, September 24, 2019
  • AANA Comments on the Department of Health and Human Services' Request for Information on Ensuring Patient Access and Effective Drug Enforcement, August 8, 2019 
  • AANA and APRN Coalition Partners Comment on Reducing Medicare Administrative Burden, August 7, 2019
  • AANA Comments on Proposed Medicare Coverage for Acupuncture, August 7, 2019
  • AANA Submits Comments for the Record for House Rural and Undeserved Communities Health Task Force, July 19, 2019
  • AANA Works with House Healthcare Innovation Caucus to Support Innovative Payment Models and the Technologies Needed to Support these Models, July 8, 2019
  • AANA Comments on CMS Co-Location Guidance, July 2, 2019
  • AANA Comments on Federal Trade Commission's Final Session of Hearings on Competition and Consumer Protection in the 21st Century, June 26, 2019
  • AANA Supports Increased Patient Access to Safe, Responsible use of MAT for Treatment of Substance and Opioid Use Disorder, June 25, 2019
  • AANA Comments on CMS Hospital Inpatient Prospective Payment System Proposed Rule, June 13, 2019
  • AANA Comments on Senate Discussion Draft on Surprise Billing, June 5, 2019
  • AANA Comments on CMS Interoperability Proposed Rule; Recommends Expanding the Availability of Health Information Will Increase Access to Safe, High Quality and Cost-Effective Anesthesia Care, May 31, 2019 
  • AANA Comments on House Energy & Commerce Discussion Draft on Surprise Billing, May 28, 2019
  • AANA Recommends Preserving Provider Nondiscrimination Language and Protecting Essential Health Benefits in Selling Health Insurance Across State Lines, May 3, 2019
  • AANA to Attend Third Meeting on HHS Pain Management Best Practices Interagency Task Force; Advocates for CRNAs Who Provide Holistic, Multi-Modal Pain Management Anesthesia Services, April 29, 2019
  • AANA Urges New York-Based Independent Health to Withdraw Its Policy on Monitored Anesthesia Care for GI Procedures, April 18, 2019
  • AANA Providers Statement for the Record to Congress on Surprise Billing, April 3, 2019
  • AANA Signs on to APRN Coalition Letter and Voices for Non-opioid Choices Letter in Response to HHS Pain Management Best Practices Inter-Agency Task Force Draft Recommendations for Acute and Chronic Pain Management, April 1, 2019
  • AANA Responds to Congressional Telehealth Caucus' Request for Information on Planning for Comprehensive Telehealth Legislation, March 29, 2019
  • AANA Recommends to Federal Agencies to Preserve Provider Nondiscrimination Language and Protect Essential Health Benefits if Changes are Made to Grandfathered Group Health Plan Regulations, March 19. 2019
  • AANA Comments on Senate Appropriations Subcommittee Hearing on Opioid Epidemic, February 28, 2019
  • AANA Supports Coverage of Medication Assisted Treatment in all Qualified Health Plans, February 15, 2019
  • AANA Calls for Recognition for All Pain Management Providers in Draft Report Released by HHS Pain Management Best Practices Inter-Agency Task Force, February 6, 2019


  • AANA Responds to HHS Final Report on Reforming America's Healthcare System through Choice and Competition, December 10, 2018
  • AANA Submits Comments on Telehealth Issues in Proposed Rule on Policy and Technical Changes to the Medicare Advantage Program, December 10, 2018
  • AANA and APRN Coalition Partners Comment on Reducing Regulatory Burden in Medicare Program, November 19, 2018
  • AANA Submits Comments to Novitas Solutions on the Draft LCD on Hyaluronan Acid Therapy, November 8, 2018
  • AANA Comments on Field Testing of MACRA Episode-Based Cost Measures, October 31, 2018
  • AANA Submits Comments on 21st Century Cures Act Electronic Health Record Reporting Program, October 9, 2018
  • AANA Submits Comments on the CMS Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems Proposed Rule, September 21, 2018
  • AANA Advocates for CRNAs to Practice to the Full Extent of their Education, Training Certification and Scope of Practice in a Statement for the HHS Pain Management Best Practices Inter-Agency Task Force Second Meeting, September 14, 2018
  • AANA Submits Comments to CMS on the Physician Fee Schedule Proposed Rule, September 6, 2018
  • AANA Congratulates Robert Wilkie on his Appointment as Secretary of the Department of Veterans Affairs, July 25, 2018
  • AANA Comments on House Healthcare Innovation Caucus Request for Information on Innovative Payment Models, July 19, 2018
  • AANA Advocates for Full Practice Authority for CRNAs in VHA Facilities in Comments Regarding VHA Directive 1123, June 26, 2018
  • AANA Requests Medicare to Address Underlying Causes of Surprise Billing in Comments on Hospital Inpatient Prospective Payment System Proposed Rule, June 19, 2018 
  • AANA Requests Meetings with Veterans' Health Administration's Carolyn Clancy and Acting VA Secretary Peter O'Rourke Regarding Supervision Requirements in VHA Directive 1123; Read AANA's Talking Points, May 31, 2018
  • AANA and AVANA Issue Joint Statement on Recent VHA Directive Regarding Anesthesia Services, May 31, 2018 (Member Login Required)
  • AANA Urges Equal Treatment of CRNAs in Direct Provider Contracting Models, May 25, 2018
  • AANA to Attend First Meeting of HHS Pain Management Best Practices Inter-agency Task Force; Advocates for CRNAs Who Provide Multi-Model Pain Management, May 24, 2018
  • AANA Provides Recommendations to Help Assure Access to Covered Medicaid Services and Promoting Consumer Choice, May 22, 2018
  • AANA Comments on Short Term, Limited Duration Insurance Proposed Rule, April 22, 2018
  • AANA Congratulates the Appointment of New CMS Innovation Center Director, April 12, 2018
  • AANA Submits Comments to House Energy and Commerce Health Subcommittee on Opioids Legislation, April 4, 2018.
  • AANA as Part of the APRN Community Providers Policy Recommendations for Removing Barriers to APRN Care and Practice to HHS, the Medicare Agency, and the House Ways and Means Committee, March 16, 2018
  • APRN Community Tells Congress that APRNs Want to Play a Key Role in Working Collaboratively Towards Comprehensive Solutions  to Curb the Opioid Epidemic, March 15, 2018 
  • AANA Comments on House Ways & Means Opioid Request, March 13, 2018 
  • AANA Submits Comments Requesting CRNAs to be Included in Qualified Health Plans Participating in Association Health Plans, March 5, 2018
  • AANA Submits Comments to Novitas Solutions on the Draft LCD for Facet Joint Interventions, March 1, 2018
  • AANA Requests Removal of Barriers to the Use of Medically Necessary CRNAs Pain Management Services in Response to CMS 2019 Draft Call Letter Regarding Medicare Part C and D, March 1, 2018
  • AANA Submits Comments to the Office of the National Coordinator for Health Information Technology's Draft Trusted Exchange Framework, February 16, 2018
  • AANA Urges Anthem to Withdraw its Policy on Anesthesia for Cataracts, February 9, 2018
  • AANA Congratulates the New Secretary of the U.S. Department of Health and Human Services and Looks Forward to Working Together to Attain our Common Goals of Increasing Access to Healthcare, Advancing Healthcare Reform and Innovation, and Making Healthcare Affordable, January 30, 2018
  • AANA Advises the FCC to Prohibit the Use of Wasteful Tele-Supervision of CRNA Services in Proposed Telehealth Rule, January 31, 2018
  • AANA Comments on Promoting Telehealth in Rural America, January 26, 2018
  • AANA Provides Recommendations for Promoting Healthcare Choice and Competition Across the United States, January 18, 2017
  • AANA Submitted a Statement for the Record on a House Ways and Means Committee Hearing Related to CMS Actions to Prevent Opioid Misuse, January 17, 2018
  • AANA and the Nursing Community Coalition sent letters to House and Senate Committees Urging Them to Support the Nursing Workforce Re-authorization Act, January 16, 2018
  • AANA Recommends Proposals for Promoting Healthcare Marketplace Innovation and Reducing Regulatory Burdens for CMS' Medicare Advantage and the Medicare Prescription Drug Benefit Programs Proposed Rule, January 8, 2018