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19.02.2013 Views

CMS-1403-FC We received several comments on our proposals with the majority from national organizations. The following is a summary of the comments received and our responses. Comment: All of the comments that we received on our proposed technical correction supported the change. The commenters agreed that the intent of the graduated NP educational qualifications was to ensure that practicing NPs and their patients were not left unable to enroll in Medicare after we adopted our rules requiring national certification and a master’s degree in nursing for enrollment. Many commenters stated that these NPs had already been recognized and practicing as Part B suppliers. The commenters also stated that the technical correction does not appear to violate the intent of the NP educational qualifications and should reduce any confusion that might still remain regarding this requirement. Response: We are finalizing the technical correction as proposed in order to clarify our requirement that effective on or after January 1, 2003, all NPs must have a master’s degree in nursing. Comment: The majority of commenters commended CMS for our proposal to recognize the DNP degree and stated that we are keeping pace with the transformation in advanced practice registered nursing education. The commenters 712

CMS-1403-FC applaud CMS for recognizing the DNP degree as a valid degree that exceeds a master’s degree in nursing and stated that recognition of the DNP degree will be positive for patients. However, some commenters cautioned against eliminating the master’s degree in nursing for NPs and CNSs and replacing it with the DNP degree only. The commenters stated that transitioning to the DNP degree as the national standard by 2015 is only a goal toward which the nursing profession will work and that it may take longer for some programs than others to address State licensing and institutional issues. Accordingly, the commenters requested that both the master’s degree in nursing and the DNP degree must be recognized by CMS as appropriate credentials for APN reimbursement. Additionally, one commenter urged CMS not to require a master’s of science in nursing (MSN) degree instead of a master’s degree in nursing. Response: As we stated in the CY 2009 PFS proposed rule, we believe that it is logical for Medicare to recognize APNs with more extensive education and experience while continuing to recognize NPs and CNSs with a master’s degree in nursing. NPs or CNSs with a doctoral degree in nursing practice should not be denied enrollment in the 713

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

We received several comments on our proposals with the<br />

majority from national organizations. The following is a<br />

summary of the comments received and our responses.<br />

Comment: All of the comments that we received on our<br />

proposed technical correction supported the change. The<br />

commenters agreed that the intent of the graduated NP<br />

educational qualifications was to ensure that practicing<br />

NPs and their patients were not left unable to enroll in<br />

Medicare after we adopted our rules requiring national<br />

certification and a master’s degree in nursing for<br />

enrollment. Many commenters stated that these NPs had<br />

already <strong>been</strong> recognized and practicing as Part B suppliers.<br />

The commenters also stated that the technical correction<br />

does not appear to violate the intent of the NP educational<br />

qualifications and should reduce any confusion that might<br />

still remain regarding this requirement.<br />

Response: We are finalizing the technical correction<br />

as proposed in order to clarify our requirement that<br />

effective on or after January 1, 2003, all NPs must have a<br />

master’s degree in nursing.<br />

Comment: The majority of commenters commended <strong>CMS</strong> for<br />

our proposal to recognize the DNP degree and stated that we<br />

are keeping pace with the transformation in advanced<br />

practice registered nursing education. The commenters<br />

712

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