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

standardization of DNP programs’ multiple accreditation<br />

processes. The commenters also stated that, and Federal<br />

recognition of an unproven nursing doctoral program seems<br />

premature given that no State licensing agency or State<br />

board of nursing <strong>has</strong> developed statutes or regulations<br />

authorizing the utilization of the DNP as a substitute for<br />

the master’s education requirement and NP or CNS<br />

certification.<br />

Response: We believe that as any new educational<br />

program develops, there are likely to be some uncertainty<br />

and inconsistency inherent in the process. However, the<br />

APN community <strong>has</strong> a stated goal of moving toward a national<br />

standard of graduating APNs from DNP programs. We do not<br />

believe that it is sensible to deny Medicare enrollment to<br />

a registered professional nurse with a DNP degree who meets<br />

all of the other qualification requirements when we enroll<br />

nurses with a master’s degree. We have relied on our<br />

contractors to enroll only those NPs and CNSs who have<br />

graduated with a master’s degree in nursing in addition to<br />

meeting other qualification standards that require State<br />

licensure and certification by a recognized national<br />

certifying body. We believe that these collective<br />

qualifications ensure that only qualified nurses with<br />

proper clinical training furnish services to Medicare<br />

715

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