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Comment Letters
2019
- 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
2018
- 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
2017
- AANA as Part of APRN Community Urges Medicare to Remove Language Prohibiting APRNs from Serving on Medicare Advisory Committee Responsible for Local Coverage Determination Development, December 20, 2017
- AANA Comments on how CRNA Multi-Modal Pain Management Services Help Reduce Patient Need for Reliance on Opioids in response to AHRQ Report on Noninvasive, Non-pharmacological Treatment for Chronic Pain
- AANA Continues to Promote CRNAs Providing Safe, High Quality and Cost Effective Healthcare in HHS Notice of Benefit and Payment Parameters Rule, November 28, 2017
- AANA Comments on Field Testing of MARCA Episode-Based Cost Measures, November 18, 2017
- AANA Submits Comments on CMS Innovation Center's New Direction, November 18, 2017
- AANA submitted a Statement for the Record on the House Energy and Commerce Subcommittee on Health hearing about MARCA, November 8, 2017.
- AANA and APRN community Recommends to Prohibit Wasteful Tele-Supervision of CRNA Services From Being Included as part of Expansion of Telehealth Services within the VA.
- AANA Comments on the Department of Health and Human Services' Draft Strategic Plan for 2018-2022, October 26, 2017
- AANA and the Nursing Community send a letter to VA Secretary Shulkin endorsing full practice authority for CRNAs in the VA, October 19. 2017
- AANA Submits Comments on Modifications to the CMS Joint Replacement Payment Model Program, October 13, 2017
- AANA Sends letter to VA Secretary Shulkin and OMB Director Mulvaney highlighting the importance of full practice authority in the VA in light of the recent reports out of Denver, October 10, 2017
- AANA Submits Comments to the Draft Interim Report from the President's Commission on Combating Drug Addition and the Opioid Crisis.
- AANA and the APRN Community Submit Comments to CMS on the Proposed Physician Fee Schedule, September 8, 2017
- AANA Submits Comments on the CMS Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems proposed rule, September 7, 2017
- AANA and APRN Coalition Comments on House Ways and Means Medicare Red Tape Relief Project, August 24, 2017
- AANA Comments on the Proposed Updates for the CMS Quality Payment Program, August 18, 2017
- AANA Recommends Implementing CRNA Full Practice Authority and Removal of Physician Supervision of CRNA Anesthesia Services to Help Reduce Regulatory Burdens, July 10, 2017
- AANA Sends Letter to President's Commission on Combating Drug Addiction and the Opioid Crisis, Demonstrating How CRNAs Provide Multimodal Pain Management Which May Reduce Patient's Need for and Reliance on Opioids, July 5, 2017
- AANA Comments on Medicare Regulatory Reforms in CMS Hospital Inpatient Prospective Payment System Proposed Rule, June 12, 2017
- AANA Requests CRNA Full Practice Authority in Response to OMB Guidance on Reforming the Federal Government, June 9, 2017
- AANA Signs on to Consumer Pain Advocacy Task Force Letter Calling for Recognition of the Relationship Between the Chronic Pain and Opioid Epidemics, June 7, 2017
- AANA Comments on Draft Federal Pain Research Strategy, June 5, 2017
- AANA Comments on CMS Episode-Based Cost Measure Development as Part of CMS Quality Payment Program, March 27, 2017
- AANA Congratulates Seema Verma on Her Appointment as Administrator of the Centers for Medicare & Medicaid Services
- AANA Submits Comments on the Centers for Medicare and Medicaid Services' Request for Information on Pediatric Alternative Payment Model Concepts, March 13, 2017
- AANA Comments on American College of Surgeon's proposed payment model, March 13, 2017
- AANA Submits Comments on Network Adequacy Regarding the Affordable Care Act Market Stabilization Proposed Rule, March 1, 2017
- AANA and APRN Organizations Call for CRNA Full Practice Authority in Response to the Department of Veterans Affairs Final Rule with Comments, January 12, 2017
- AANA Comments on CMS Revised Patient Relationship Categories and Codes as Part of CMS Merit-Based Incentive Payment Program, January 3, 2016
2016
- AANA and APRN Coalition Submit Comments to CMS on the MACRA Final Rule, December 16, 2016
- AANA Submits Comments to HHS on the Proposed Measures and 2020 Targets for the National Action Plan for Adverse Drug Event Prevention, November 15, 2016
- AANA Submits Comments to Novitas Solutions on the Draft LCD for Epidural Injections, October 21, 2016
- AANA Submits Comments to CMS on Episode Payment Models, September 27, 2016
- AANA Submits Comments on HHS Request for Information on Opioid Prescriber Education, September 2, 2016
- AANA Submits Comments on the Physician Fee Schedule Proposed Rule for CY 2017, September 1, 2016
- AANA Submits Comments on the CMS Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems proposed rule, August 30, 2016
- AANA Comments on CMS Episode Groups as Part of CMS Merit-Based Incentive Payment Program, August 25, 2016
- AANA Urges Medicare Administrative Contractor Novitas to Withdraw its FAQ on Medical Direction, August 12, 2016
- AANA Comments on CMS Patient Relationship Categories and Codes as Part of CMS Merit-Based Incentive Payment Program, August 12, 2016
- AANA Submits Comments to CMS on Updates to Hospital and CAH Conditions of Participation Proposed Rule, August 4, 2016
- AANA, APRN organizations, and AVANA Request the VA Finalize and Implement their Proposal of Full Practice Authority for APRNs in VHA Facilities because it Ensures Access to Safe and High-Quality Care for Veterans, July 22, 2016
- AANA and APRN Organizations Comments on CMS's MACRA Quality Payment Program Proposed Rule, June 27, 2016
- AANA Submits Comments to CMS on MACRA Quality Payment Program Proposed Rule (See also Appendix A), June 21, 2016
- AANA Submits Comments to the Health Care Payment Learning and Action Network on Draft White Paper on Cardiac Care, June 14, 2016
- AANA Submits Comments on Medication Assisted Treatment for Opioid Use Disorders Proposed Rule, May 31, 2016
- AANA Submits Comments to the Office of the National Coordinator for Health Information Technology on their Request for Information on Assessing Interoperability for MACRA, May 27, 2016
- AANA Submits Comments to Health Care Learning and Action Network on draft White Paper on Maternity Care, May 20, 2016
- AANA Leads APRN Workgroup Response to the Payment Technical Advisory Committee (PTAC) on its Draft Review Process for Proposals, May 13, 2016
- AANA Submits Comments on the Proposed Rule Regarding Program Integrity Enhancements to the Provider Enrollment Process in Medicare, Medicaid and CHIP, April 13, 2016
- AANA Urges Medicare to Direct WPS to Immediately Cease Auditing CRNAs in Missouri for Legal Use of QZ Billing Modifier, April 11, 2016
- AANA Submits Comments to the Health Care Payment Learning and Action Network on draft White Paper on Elective Joint Replacement, March 28, 2016
- AANA Submits Comments to WPS on Lumbar Epidural Injections, March 17, 2016
- AANA Submits Comments to Novitas Solutions on the Draft LCD for Lumbar Epidural Injections, February 26, 2016
- AANA Submits Comments to CMS on their draft Quality Measure Development Plan that Supports the Transition to MIPS and APMs, February 26, 2016
- AANA Submits Comments to CDC on Draft Guideline for Prescribing Opioids, January 11, 2016
2015
- AANA as part of a national coalition on graduate nurse education provides comments to CMS regarding the evaluation of the Graduate Nurse Education Demonstration Program, December 18, 2015
- AANA and APRN Organizations Submit Letters to HHS Commenting on their Notice of Benefits and Payment Parameters proposed rule, December 18, 2015
- AANA Submits Comments on CMS' Final Rule on Electronic Health Records Stage 3 Meaningful Use, December 4, 2015
- AANA Joins APRN Organizations in Requesting that the Health Care Payment Learning and Action Network's Alternative Payment Model Frankework Note and Address Barriers to the Use of APRNs, November 20, 2015
- AANA Submits Comments to Palmetto GBA on Facet Joint Injections (read draft LCD), November 17, 2015
- AANA and APRN Groups Submit Comments to CMS on MACRA Implementation, November 17, 2015
- AANA Submits Comments to CMS on MACRA Implementation, November 11, 2015
- AANA Submits Comments to Novitas Solutions on Facet Joint Injections (read draft LCD) and on Nerve Blockade (read draft LCD), October 30, 2015
- AANA congratulates incoming House Speaker Paul Ryan (R-WI).
- AANA joins eight APRN organizations in support of the bipartisan two-year budget agreement (HR 1314) before Congress, October 28, 2015
- AANA joins 196 healthcare organizations in support of increased funding to the Agency for Healthcare Research and Quality (AHRQ), which is slated for a major funding reduction, October 22, 2015
- AANA joins 10 APRN organizations in supporting the VHA Independent Assessment Recommendation that urges the VHA to adopt APRN Full Practice Authority policy, October 6, 2015
- AANA and APRN groups Submit Comments on the Physician Fee Schedule Proposed Rule for CY 2016, September 4, 2015
- AANA Submits Comments on the Medicare Comprehensive Care for Joint Replacement Payment Model, September 4, 2015
- AANA supports a proposal offering a grace period for submitting claims with ICD-10 codes, August 26, 2015
- AANA responds to attack on CRNA care from 17 members of Congress, August 18, 2015
- AANA Submits Comments to CMS on the Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs Proposed Rule for CY 2016, August 18, 2015
- AANA submits public testimony on the impact of the Institute of Medicine Report, “The Future of Nursing: Leading Change, Advancing Health” on access to CRNA services, July 28, 2015
- AANA Submits Comments to CMS on a Medicaid Managed Care proposed rule calling for Medicaid managed care plans fully recognize CRNAs, July 27, 2015
- AANA provides support for Senate confirmation of Andy Slavitt as Administrator of CMS, July 9, 2015
- AANA Submits Comments to Novitas Solutions on Drugs of Abuse Testing, July 9, 2015
- AANA and APRN organizations Support 21st Century Cures Initiative, June 29, 2015
- AANA Submits Comments to WPS Medicare on Facet Joint Injections, June 26, 2015
- AANA joins 144 Healthcare organizations in support for AHRQ funding, June 22, 2015
- AANA provides recommendations to Senate Finance Committee chronic care working group, June 22, 2015
- AANA Submits Comments to CMS on the Hospital Inpatient Prospective Payment System Proposed Rule, June 12, 2015
- AANA joins Nursing Community in Supporting Nurse Anesthesia Traineeship and Advanced Nursing Education program funding reauthorization, June 11, 2015
- AANA and APRN colleagues request that trade legislation not be financed by cuts to CRNAs and Medicare provider payments, June 9, 2015
- AANA and 12 APRN organizations submitted testimony to Senate Veterans’ Affairs Committee on legislation that extends full practice authority to APRNs in the VHA, but excludes CRNAs, June 2, 2015
- AANA submits comments on ways to improve Medicare competition to key House Committee, June 1, 2015
- AANA submits comments to CMS on the Stage 3 Electronic Health Record Incentive Program proposed rule, May 27, 2015
- AANA expresses concern for HR 2138, which would increase costs for rural hospitals where CRNAs predominate, May 21, 2015
- AANA Requests that the Draft NIH National Pain Strategy Address Barriers to CRNA Pain Management Practice and Education, May 19, 2015
- AANA and APRN Organizations Comment on the Draft NIH National Pain Strategy, May 19, 2015
- AVANA Submits Testimony in Support of the VHA Nursing Handbook Full Practice Proposal to Key House Committee, May 15, 2015
- A Bipartisan Group of Senators Send Support to the Veterans Health Administration for CRNAs and APRNs Practicing as Full Practice Providers, May 5, 2015
- AANA Sends Support for Medicare Coverage of Anesthesia Services for Therapeutic Colorectal Cancer Screenings, May 5, 2015
- AANA Submits Comments to the American Medical Association CPT Editorial Panel Regarding Proposals on Epidural Injections and on Injections at the Caudal and Lumbar Levels, April 23, 2015
- AANA and APRN organizations urge the Senate to pass a SGR fix to avoid a 21% payment reduction for CRNAs and physicians, April 13, 2015
- AANA and APRN groups urge Congress to pass a SGR fix to avoid CRNA and Physician Medicare payment reductions, March 24, 2015
- AANA Congratulates Dr. Mary Wakefield on her appointment of Acting Deputy Secretary of Health for the Department of Health and Human Services, March 17, 2015
- The AANA, and close to two dozen other healthcare organizations, urged lawmakers to amend the tax code to provide CRNA students tax free status for student loan repayments from the Indian Health Service, March 9, 2015
- AANA was joined by 40 nursing organizations including 12 APRN organizations in supporting the "Improving Veterans Access to Quality Care Act." This legislation would grant all APRNs, including CRNAs, full practice authority in the VHA, March 4, 2015
- AANA makes a request to CMS that Medicare Advantage plans adopt alternative payment systems that recognize and reward all qualified healthcare providers, including CRNAs, March 4, 2015
- AANA Submits Comments to the FTC Regarding Their Healthcare Workshop on Examining Health Care Competition in the Health Care Industry, February 16, 2015
- AANA and APRN Organizations Comment on the “21st Century Cures Act,” requesting provider-neutral language and warning against tele-supervision of CRNAs, February 11, 2015
- AANA urges Senate Veterans’ Affairs Committee to add CRNAs to legislation extending full practice authority to APRNs in the VHA, February 10, 2015
- AANA, along with other national nursing organizations, urges CMS to remove physician requirement as medical director for clinical management and oversight in accountable care organizations, February 2, 2015
- AANA urges HHS Secretary to include CRNAs in efforts on
value-based payment, January 29, 2015 - AANA, along with other APRN organizations, recommend removing a provision in the Hospital Improvements for Payment discussion draft that would increase health care costs in rural America, January 27, 2015
- AANA joins other APRN organizations in urging Congress to repeal the SGR and reform Medicare payment for APRNs, January 20, 2015
- AANA Thanks Marilyn Tavenner for Her Work As CMS Administrator, January 16, 2015
- AANA Congratulates Andrew Slavitt on His Appointment As Acting Administrator of the Centers for Medicare and Medicaid Services, January 16, 2015
- The AANA and other APRN organizations recommend the National Association of Insurance Commissioners require APRNs be included in Health Network Carrier Plans, January 12, 2015
- AANA Submits Comments to the National Association of Insurance Commissioners on Revisions to their Health Benefit Plan Access and Network Adequacy Model Act, January 9, 2015