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<strong>CMS</strong>-1403-FC<br />

requires advanced practice nurses (APNs) to have a master’s<br />

degree in a defined clinical area of nursing from an<br />

accredited educational institution in order to allow CNSs,<br />

alternatively, to meet these requirements with a DNP<br />

doctoral degree.<br />

In the proposed rule, we acknowledged that we are<br />

aware that some educational institutions are offering<br />

programs to prospective NPs and CNSs that allow students to<br />

move from a baccalaureate degree in nursing directly to the<br />

doctoral degree in nursing where they earn a DNP as a<br />

terminal clinical doctoral degree. Therefore, some APNs<br />

who earn the DNP degree do not receive a master’s degree in<br />

nursing even though they will have met all of the<br />

educational requirements for a master’s degree in nursing,<br />

in addition to the preparation that merits them the DNP<br />

degree. We noted that a Wall Street Journal article<br />

(published April 2, 2008) stated that by the year 2015, the<br />

American Association of Colleges of Nursing aims to make<br />

the doctoral degree the standard for all new APNs. We<br />

believe that it is logical for Medicare to recognize APNs<br />

with more extensive education and training. Therefore, we<br />

proposed to permit qualified APNs with the DNP degree to<br />

enroll and receive Medicare Part B payment as NPs and CNSs.<br />

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