Federal Advocacy Library
The American Nurses Association (ANA) Policy & Government Affairs department engages in public policy making to promote the wellbeing of nurses, demonstrate the value of nursing domestically, and improve the nation’s healthcare system for the benefit of all. One of the primary ways ANA advances these goals is by deploying dedicated staff to advocate and lobby Congress, the White House, and Federal Agencies on behalf of registered nurses. ANA also facilitates engagement for our members to advocate for their policy priorities with lawmakers.
Our mission is to be involved at all levels of the policymaking process from the time initiatives are conceived, while they are debated, and during the rule making and implementation process. In order to both advocate for policies and bills to become law and subsequently ensure they are implemented correctly, staff teams focus our federal advocacy along two tracks, Legislative and Regulatory.
Federal Legislative Advocacy
On the Legislative Advocacy side, to be successful with passing and implementing our policy priorities, ANA remains nonpartisan and works diligently to form relationships with elected officials and staff of all political stripes in Congress. We meet with elected officials on these issues every day to make sure they understand ANA’s priorities. While we may disagree on certain issues, we remain steadfast to not be disagreeable – the person you disagree with on one issue may be your biggest champion on another in the future. This is how we advance the nursing profession and improve the lives of patients and nurses. You can view our letters to Congress and other nursing coalition letters below:
119th Congress (2025-2026)
Advocacy Groups Send Letters in Support of the ICAN Act to Key House and Senate Committees
ANA joined 263 advocacy organizations to send letters to Key House and Senate committees in support of the Improving Care and Access to Nurses (ICAN) Act. The bill would increase patient access to care by removing outdated and unnecessary federal barriers on services provided by advanced practice registered nurses under the Medicare and Medicaid programs. The list of signatories include all 51 of ANA’s constituent/state nursing associations and 29 of its organizational affiliates.
ANA Sends Letter Outlining Priorities for the 119th Congress
ANA leaders sent a letter to Congressional Leadership about our top priorities for the 119th Congress. These include investing in nursing education, recruitment, and retention as well as expanding access to care.
118th Congress (2023-2024)
ANA Sends Letter to Congressional Leadership Outlining Year-End Priorities
ANA sent a letter to Congressional Leadership detailing it's year-end legislative priorities. These priorities aim to address cricial issues facing the nursing profession.
ANA Sends Letter to House Committee on Energy and Commerce Opposing H.J. Res. 139
ANA sent a letter to the House Committee on Energy and Commerce opposing H.J. Resolution 139, which would overturn the Centers for Medicare and Medicaid Services’ (CMS) final rule on safe staffing standards in long-term care facilities.
ANA Shares Feedback with Chairman Wyden on Ways to Keep Labor & Delivery Units Open
ANA recently submitted comments to Senate Finance Committee Chairman Ron Wyden (D-OR) on the Keeping Obstetrics Local Act. This bill draft aims to address several factors that are resulting in the closure of labor and delivery units around the country.
ANA Responds to Request for Information on the Pay PCPs Act
ANA recently submitted a letter to Senators Sheldon Whitehouse (D-RI) and Bill Cassidy, MD (R-LA) that highlights how Congress can expand Medicare patients’ access to primary care services provided by APRNs. In the letter, ANA calls on Congress to reform how CMS determines reimbursement rates for APRNs and ensure that nurses have a seat at the table when those decisions are made.
ANA sent a letter to House and Senate Leadership urging Congress to oppose ongoing efforts to overturn the Centers for Medicare and Medicaid Services’ (CMS) final rule on safe staffing standards in long-term care facilities.
ANA Sends Letter to House Committee on Education and the Workforce Supporting H.R. 618
ANA sent a letter to Committee Chairwoman Foxx and Ranking Member Scott supporting the Improving Access to Workers' Compensation for Injured Federal Workers Act (H.R. 618).
ANA Sends Letter to Senate HELP Supporting the Dr. Lorna Breen Reauthorization Act
ANA sent a letter to the Senate HELP Committee supporting the Dr. Lorna Breen Health Care Provider Protection Reauthorization Act to ensure nurses and health care workers have the health mental tools and resources they need.
ANA Shares Nursing Perspective on Medicare Part B Payment Reform
ANA recently submitted a letter to the Senate Finance Committee that outlines ways that Congress can ensure Medicare patients’ access to nursing care through Medicare Part B Payment Reform.
ANA Sends Letter Opposing H.R. 7513 to Protect Nurses in Long-Term Care Facilities
ANA sent a letter to Congressional leadership opposing the Protecting America's Seniors' Access to Care Act (H.R. 7513) which would prohibit the Centers for Medicare and Medicaid Services (CMS) from issuing a rule on safe staffing standards in long-term care facilities.
ANA Sends a Letter to Congressional Leaders Outlining our 2024 Priorities
ANA submitted a letter to Congress that highlights several of the organization’s congressional priorities for 2024. The priorities include expanding and retaining the nursing workforce, addressing regulatory barriers to patients’ access to timely, quality care, and improving maternal health equity.
ANA Statement for the Record to the House VA Committee on Rural Access for Veterans
ANA attended the House VA Committee hearing on January 11 titled, “Rural Access: Is VA Meeting All Veterans Where They Live?”. We also submitted an official statement for the record to the Committee.
ANA Replies to Ways & Means Committee Chairman's RFI on Improving Rural Health
ANA submitted a letter documenting the increasingly dire challenges that the nation’s rural population, workforce, and health care infrastructure are facing, and potential solutions.
ANA Sends Letter to Senate HELP Leaders on Draft Legislation to Improve the Health Care Workforce
ANA sent a letter to Chairman Bernie Sanders (I-VT) and Senator Roger Marshall (R-KS) supporting their bipartisan legislation to improve the health care workforce along with suggestions on how to make it stronger.
ANA weighed in on giving CRNAs full practice authority within the VA
AARP Shows their Support for the Improving Care and Access to Nurses (ICAN) Act
AARP advocates for more than 100 million Americans aged 50 over older. They support the ICAN Act as it addresses barriers to care in the Medicare and Medicaid programs for Advanced Practice Registered Nurses to provide care.
ANA Responds to the Request for Information Regarding the Pandemic and All-Hazards Preparedness Act
The Pandemic and All-Hazards Preparedness Act (PAHPA) is set to be reauthorized later this year. PAHPA is critical to safeguard public health and support improvements in the nation’s preparedness and response capabilities for public health and medical emergencies. ANA submitted comments to the Senate HELP Committee.
ANA Responds to the Request for Information Regarding the Pandemic and All-Hazards Preparedness Act
The Pandemic and All-Hazards Preparedness Act (PAHPA) is set to be reauthorized later this year. PAHPA is critical to safeguard public health and support improvements in the nation’s preparedness and response capabilities for public health and medical emergencies. ANA submitted comments to the House Committee on Energy and Commerce.
ANA Statement for the Record to the Senate HELP Committee on Health Care Workforce Shortages
ANA attended the Senate HELP Committee hearing on February 16 titled, “Examining Health Care Workforce Shortages: Where Do We Go From Here?”. We also submitted an official statement for the record to the Committee.
ANA Sends a Letter to Congressional Leaders Outlining our Priorities for the 118th Congress
ANA leaders recently sent a letter to Congressional leaders about our top priorities for the 118th Congress. While we will be tackling a myriad of issues, we highlighted the three following topics: ensuring safe workplaces, improving patient access to care, and strengthening the nursing workforce.
Federal Regulatory Advocacy
On the Regulatory Advocacy side, subject matter experts on various policy issues actively engage on federal agency actions, regulations, and rules affecting registered nurses, the profession, your patients, and public health. We regularly engage with the Centers for Medicare and Medicaid Services and other key agencies within the Department of Health and Human Services to amplify the voice of nursing in federal health policy. Other key agencies for nursing advocacy include the Occupational Safety and Health Administration within the Department of Labor, and the Veterans Health Administration within the Department of Veterans Affairs. Below, you can read our comment letters to various agencies to see how we ensure the nursing perspective is always being considered.
2025 ANA Regulatory Comments
ANA Sends Letter to New HHS Secretaty
On March 3, ANA sent Secretary Kennedy a letter highlighting nurses vital role in healthcare and the Association's 2025 regulatory and policy priorities which include improving outcomes and access as well as shaping payment strategies to account for the direct impacts of nursing care.
ANA Comments on Proposed 2026 Medicare Advantage Rule
On January 25, the ANA submitted comments in response to CMS’ proposed plan year 2026 Medicare Advantage rule. ANA’s comments on focused on providing Medicare and Medicaid coverage for obesity medication, ensuing equitable access to behavioral health, safeguarding network adequacy, and guaranteeing proper use of artificial intelligence in healthcare.
ANA Details 2025 Policy Priorities
The American Nurses Association detailed their policy and regulatory priorities for 2025 which include promoting a robust nursing workforce, championing health care access and outcomes, and more.
2024 ANA Regulatory Comments
ANA Comments on 2025 Hospital Outpatient Prospective Payment System Proposed Rule
On September 5, ANA submitted comments to the Centers for Medicare and Medicaid Services on the Hospital Outpatient Prospective Payment System (HOPPS) proposed rule. ANA’s comments included reimbursement, telehealth, maternity care, and payment adjustments for PPE.
ANA Comments on 2025 Physician Fee Schedule Proposed Rule
On September 5, ANA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the 2025 Physician Fee Schedule proposed rule. The comments urge CMS to appropriately and adequately value the nurse and nursing services, make permanent flexibilities in telehealth, resource and recognize the nurse in patient screenings, reimburse appropriately for vaccine administration, and offer feedback to proposed changes in quality programs.
ANA letter to DHS on adding nursing degrees as STEM degrees
On September 3, ANA submitted a sign-on letter to the Department of Homeland Security (DHS), urging them to add nursing degrees to their STEM Designated Degree List. Nursing is an important STEM profession that advances health and science across many disciplines. The Department of Veterans Affairs (VA) has already included nursing degrees on their list and ANA is asking all federal agencies to align with the VA’s system.
ANA Comments on 2025 End-Stage Renal Disease Prospective Payment System Rule
On August 26, ANA submitted comments to the Centers for Medicare and Medicaid Services (CMS) addressing the 2025 End-Stage Renal Disease Prospective Payment System proposed rule. ANA urged CMS to work with nephrology nurses to solve staffing challenges and increase access to high-quality in home dialysis care.
ANA Comments on 2025 Home Health Payment Rule
On August 20, ANA submitted comments on the Centers for Medicare and Medicaid Services’ proposed 2025 Medicare payment rule for Home Health Agencies. ANA’s comment letter 1) supports proposed measures to advance health equity; 2) urges CMS to account for nurse value in the home health value-based purchasing model; 3) calls for nurse engagement in service acceptance plans; and 4) recommends CMS consider healthcare personnel in respiratory infection reporting. In addition, ANA opposes therapists conducting nursing care assessments in home health.
ANA Comments on Proposed Rule to Reschedule Cannabis
On July 17, ANA submitted comments to the Department of Justice and Drug Enforcement Administration supporting their proposed rule that would reschedule cannabis from a Schedule I drug, the category where a drug has no medical benefits, to a Schedule III drug where the drugs have shown some medical benefits. This proposed rule would open much needed authority and funding for research on the therapeutic uses of cannabis which ANA has supported since 1996.
ANA Comments on Physician-Focused Model Technical Advisory Committee
On July 15, ANA submitted comments in response to the Physician-Focused Payment Model Technical Advisory Committee (PTAC) request for input on challenges caring for patients with complex condition or serious illnesses. ANA’s comments focused on characteristics of these populations, challenges in caring for them, and encouraging use of alternative payment models.
ANA Comments on Proposed 2025 Hospital Inpatient Prospective Payment System Rule
On June 7, ANA submitted comments on the Centers for Medicaid Medicare Services (CMS) proposed Hospital Inpatient Prospective Payment System (IPPS) proposed 2025 rule. ANA’s comment letter focused on payment incentives, respiratory illness incentives, health equity, maternal health, and climate change.
ANA Comments on 2025 Inpatient Psychiatric Facilities Proposed Payment Rule
On May 28, ANA submitted comments to the Centers for Medicare and Medicaid Services (CMS) addressing the 2025 Inpatient Psychiatric Facilities Proposed Payment Rule. In the comments ANA urged the agency to continue advancing health equity throughout the program, advance a proposed quality measure, and find solutions to increase pay transparency for nurses.
ANA Comments in Response to Medicare's 2025 Payment Rule for Hospice Providers
On May 28, ANA submitted comments on the Centers for Medicare and Medicaid Services’ proposed 2025 Medicare payment rule for hospice providers. ANA comments on proposals aimed at improving equity in Medicare’s hospice program, and on proposed implementation of the new Hospice Outcomes and Patient Evaluation (HOPE) assessment tool.
ANA Comments in Response to Medicare's Proposed 2025 Payment Rule for Skilled Nursing Facilities
On May 28, ANA submitted comments on the Centers for Medicare and Medicaid Services’ proposed 2025 Medicare payment rule for Skilled Nursing Facilities (SNFs). ANA’s comment letter 1) Focuses on initiatives to advance equity and healthcare quality in SNFs; 2) Urges CMS to leverage specific quality metrics to inform implementation of minimum staffing standards; and 3) Calls for regulatory improvements in transparency in SNF reporting of cost expenditures for nursing care.
ANA Responds to CMS Request for Information on Medicare Advantage Data
On May 21, ANA submitted comments in response to the Centers for Medicaid Medicare Services (CMS) request for information (RFI) on Medicare Advantage data. ANA’ comments focused on ensuring network adequacy and on the impact of consolidation in health care on Medicare Advantage
ANA Responds to Request for Information on Consolidation of Health Care Markets
On April 23, ANA submitted responses to the multi-agency request for information (RFI) regarding consolidation of health care markets. ANA’s comments focused on consolidation, private equity, and possible policy approaches.
ANA Letter to OSHA on Workplace Violence Prevention
On April 1, ANA together with 59 affiliate and partner nursing organizations submitted a sign-on letter to the Occupational Safety and Health Organization (OSHA) urging the quick release of their Workplace Violence Prevention for Health Care and Social Assistance Standard.
ANA Details 2024 Policy Priorities
Earlier this year, ANA detailed their policy and regulatory priorities for 2024 which include promoting a robust nursing workforce and health equity as well as removing practice barriers for APRNs and shaping payment strategies.
ANA Comments on Equity of Emergency Care Proposed Quality Measure
On February 16, ANA submitted comments on a proposed Centers for Medicare and Medicaid Services (CMS) quality measure to address inequitable access to timely quality care in emergency departments. ANA’s comments supported the measure goals and the importance of equitable access for all vulnerable populations. The comments responded to posed questions regarding alternative outcomes, score calculation and more. ANA urged the measure to holistically and realistically address the boarding and understaffing problems that contribute to inequitable emergency department care.
ANA Comments on the CMS Notice of Benefits and Payment Parameters 2025 Draft Rule
On January 5, ANA submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the Notice of Benefit and Payment Parameters for 2025 draft rule. ANA’s comments focused on three main issues. The first thanked CMS for their focus on health equity, the second in ensuring that advanced practice registered nurses (APRNs) are included in network adequacy standards, and the third is on federal telehealth policy and ensuring that advances in telehealth are maintained even though the pandemic is over.
2023 ANA Regulatory Comments
ANA Comments on NINR RFI on Nursing Research in Climate and Health
ANA submitted comments to a Request for Information (RFI) issued by the National Institute of Nursing Research (NINR) on nursing research in climate and health. ANA used the opportunity to comment to highlight the association's recently updated position statement on climate change. The comments centered on conveying that ANA holds that climate change is a critical public health issue that requires urgent action to mitigate its impact on human health and well-being.
ANA, along with 25 state members and organizational affiliates, submitted comments November 3 to the Center for Medicare & Medicaid Services (CMS) on a proposed rule that will implement minimum staffing standards in LTC facilities. In the letter, the groups expressed support for the rule while offering refinements to the proposal. The comments encouraged CMS to finalize its proposal to have a RN onsite 24/7, include LPNs in the staffing standards, work closely with facilities to ensure compliance with the standards, and work closely with the nursing community to address persistent staffing challenges and needs.
ANA Comments on CMS Long-Term Care (LTC) Facility Minimum Staffing Rule.
ANA submitted comments November 3 to the Center for Medicare & Medicaid Services (CMS) on a proposed rule that will implement minimum staffing standards in LTC facilities. In the letter, ANA expressed support for the rule while offering refinements to the proposal. ANA was especially pleased to see CMS propose to require an RN onsite 24/7, a provision the association has long advocated for. In addition, comments encouraged CMS to include LPNs in the staffing standards, work closely with facilities to ensure compliance with the standards, and work closely with nurses to address persistent staffing challenges and needs.
ANA Comments on 2024 Physician Fee Schedule Proposed Rule.
On September 6, ANA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the 2024 Physician Fee Schedule proposed rule. The comments thank CMS for changes to expand access to APRNs and telehealth. ANA urges CMS to recognize and value the critical role of RNs in successful quality measure outcomes and advancing health equity throughout the Medicare program.
On August 23, ANA submitted comments to the HICPAC which advises the Centers for Disease Control and Prevention (CDC) on infection control guidance. The comment letter urges HICPAC and CDC to establish clear and specific protection mandates to ensure the safety of nurses and all healthcare professionals.
ANA Comments on Proposed Rule on Short-Term, Limited Duration Insurance Plans
ANA submitted August 22 comments to the Department of Health and Human Services expressing support for a proposed rule that would revert 2018 rulemaking that expanded the sale and use of short-term, limited duration insurance plans. This rule would better delineate those plans from comprehensive coverage plans that are subject to the protections outlined in the Affordable Care Act.
ANA Comments on CY2024 Proposed Payment Rule for Medicare Home Health Care
On August 22, ANA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed FY24 prospective payment rule for Medicare Home Health Care. In the letter, ANA urges CMS to evaluate access to RN care in the home and supports proposed modifications to quality reporting. Comments also recommend CMS’ continued engagement with nurses on strategies to promote equity in home health care.
ANA Comments on FY24 End-Stage Renal Disease (ESRD) Prospective Payment System Proposed Rule.
On August 22, ANA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed FY24 ESRD Prospective Payment System. The comments urge CMS to invest in and support the essential role of nephrology nurses in the ESRD program and to finalize proposed health equity measures in the ESRD Quality Incentive Program.
ANA Comments to CMS on CA’s Medicaid Waiver Application to Improve Reproductive Health Care Access
On July 11, ANA submitted comments to the Centers for Medicare & Medicaid Services (CMS) supporting a federal waiver to expand access to reproductive health care in California’s Medicaid program. The letter urged CMS to work with the state on a final plan that also promotes nurse participation in the waiver program.
ANA Comments in Response to Medicaid's Managed Care Access Rule
ANA submitted June 27 comments to the Centers for Medicare & Medicaid Services proposed rule on Medicaid access in the managed care delivery system. In its comments, ANA urged CMS to ensure that plans that preserve access to services provided by advanced practice registered nurses (APRNs) are included in beneficiary provider networks and that payment rate transparency efforts encourage direct payment and parity for APRN services. ANA also urged the agency to include APRNs in any conversation and effort to address health equity.
ANA Comments in Response to Medicaid's Proposed Fee for Service (FFS) Access Rule
ANA submitted June 27 comments to the Centers for Medicare & Medicaid Services proposed rule on Medicaid access in the FFS delivery system. In its comments, ANA urged CMS to ensure that access to services provided by advanced practice registered nurses (APRNs) are included in beneficiary provider networks and that payment rate transparency efforts encourage direct payment and parity for APRN services. ANA also urged the agency to include APRNs in any advisory groups tasked with analyzing payments, as well as any conversations and efforts to address health equity.
ANA submitted June 2 comments on the Centers for Medicare and Medicaid Services requested comments on its proposed 2024 Medicare payment rule for Skilled Nursing Facilities (SNFs). In response, ANA’s comment letter 1) Provides feedback on the agency’s SNF staffing action; 2) Urges adoption of the Long-Stay Hospitalization measure for the Value-Based Payment Program; and 3) Encourages CMS to work closely with nurses on reporting measures and subsequent work to address health equity.
ANA Comments on FY24 Inpatient Psychiatric Facilities Prospective Payment System Proposed Rule
ANA submitted comments to the Centers for Medicare & Medicaid Services on the Medicare Program's FY 2024 Inpatient Psychiatric Facilities Prospective Payment System. The comments support continued encouragement of COVID-19 vaccination for health care personnel and inclusion of new health equity measures to improve care for all in the program.
ANA submitted comments to the Occupational Safety and Health Administration (OSHA) regarding the Small Business Advocacy Review of a proposed workplace violence prevention standard for health care and social assistance. The comments urged OSHA to continue the rulemaking process and release a full proposed regulation and explained why this standard is important for nurses.
ANA Comments on the Federal Trade Commission Proposed Rule to Ban Non-Compete Clauses
ANA submitted comments to the Federal Trade Commission (FTC) in support of their proposed rule banning non-compete clauses with limited exceptions where at least one party has ownership interests. ANA’s comments focused on the facts that non-compete clauses are detrimental for nurses, how most nurses do not have access to information that non-compete clauses were originally intended to protect, and how non-compete clauses worsen the nurse shortage.
ANA Comments on Safeguarding the Rights of Conscience as Protected by Federal Statutes Proposed Rule
ANA submitted comments on the Department of Health and Human Services' (HHS) proposed rule, Safeguarding the Rights of Conscience as Protected by Federal Statutes. ANA's comments explained the guiding principles of the Code of Ethics for Nurses and addressed the need for further processes from HHS to ensure patient care is never delayed by a conscience objection.
ANA Comments on English Language Proficiency for Foreign Educated Nurses
ANA submitted comments to the Health Resources and Services Administration (HRSA) in continued support of testing and minimum score requirements in English language proficiency for foreign educated nurses.
ANA Comments on Revisions to Part 2 Confidentiality Requirements, Jan. 27, 2023
ANA submitted comments on proposed updates to Confidentiality of Substance Use Disorder (SUD) Patient Records under 42 CFR part 2 (“Part 2”), which mainly proposed to better align Part 2 with existing Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy, Breach Notification, and Enforcement Rules. ANA expressed support for the proposed changes but encouraged the agency to provide more information and education to providers around stigma, privacy, and legal concerns faced by SUD patients.
ANA Comments on Notice of Benefit and Payment Parameters for 2024, Jan. 27, 2023
ANA submitted comments on the proposed Notice of Benefit and Payment Parameters for qualified health plans (QHPs) offered on the federal and state-based marketplaces for the 2024 plan year. ANA’s comments focused on urging the agency to ensure APRNs are adequately and appropriately considered in QHP provider networks, especially to increase access to medication-assisted treatment for opioid use disorders. ANA also urged the agency to work closely with nurses to address health equity barriers and challenges within the marketplaces.
The Agency for Healthcare Research and Quality (AHRQ) issued a Request for Information (RFI) seeking feedback on advancing patient and healthcare workforce safety through the development of a National Healthcare System Action Alliance to Advance Patient Safety. ANA submitted comments that urged the agency to address long-standing nurse and health care workforce safety issues, including workplace violence and inadequate staffing.
ANA Regulatory Comments (2020-2022)
2022
The Centers for Medicare & Medicaid Services (CMS) issued a request for information (RFI) seeking feedback on health care access, health equity, understanding provider experiences, and the impact of the COVID-19 pandemic. ANA submitted comments that urged the agency to make permanent the COVID-19 waivers, look to nurses as they seek approaches for addressing health equity, and remove regulatory barriers to practice.
ANA Comments on Nondiscrimination Proposed rule
The Department of Health and Human Services (HHS) issued a proposed rule reinstating and reinforcing nondiscrimination in health care programs, as protected under Section 1557 of the Affordable Care Act. This rule, if finalized, reverses previous rulemaking which limited certain nondiscrimination protections. In its comments, ANA expressed support for the proposed provisions and urged the agency to finalize the rule.
ANA Comments on the CY 2023 Physician Fee Schedule
The Centers for Medicare & Medicaid Services (CMS) released the CY 2023 Physician Fee Schedule proposed rule. ANA provided comments detailing how CMS should finalize proposals that support and pay for services provided through telehealth technologies and behavioral health, substance use disorder, and opioid use disorder treatment. The association also urged the agency to refine and develop quality measures that accurately capture nursing services, as well as, support provider participation and health equity in the Medicare Shared Savings Program. Other comments focused on incentivizing nurse pay in clinical labor pricing proposals, accepting CPT recommendations, and other issues of importance for nurses.
ANA Comments on Proposed Changes to Clinical Laboratory Improvement Amendements (CLIA)
The Centers for Medicare & Medicaid Services (CMS) released a proposed rule updating the CLIA fees and associated regulations. As the agency works to finalize the rule, ANA urged CMS to codify existing testing personnel qualifications and not categorize advanced practice registered nurses as midlevel practitioners.
ANA Letter to CMS in Response to Conditions of Participation Proposed Rule
In a Federal Register Notice published on July 6, 2022, the Centers for Medicare and Medicaid Services (CMS) requested comments on the proposed rule creating Rural Emergency Hospitals. In response, ANA's comment letter looks at 1) ensuring proper nurse staffing 2) services offered at rural emergency hospitals 3) ensuring full practice authority for APRNs and 4) discharge services.
In a Federal Register Notice published on May 10, 2022, the Centers for Medicare and Medicaid Services (CMS) requested comments on its proposed 2023 Medicare payment rule for Inpatient Prospective Payment Systems. In response, ANA’s comment letter looks at 1) future inclusion of health equity performance in the hospital readmission reduction program 2) current assessment on climate change impacts on outcomes, care, and health equity 3) principles for measuring healthcare quality disparities across CMS quality programs 4) establishing a publicly reported designation to capture the quality and safety of maternity care and 5) payment adjustments for domestically made NIOSH approved n95 surgical respirators.
In a Federal Register notice published on April 15, 2022, the Centers for Medicare and Medicaid Services requested comments on its proposed 2023 Medicare payment rule for Skilled Nursing Facilities (SNFs). In response, ANA’s comment letter 1) Supports required reporting of flu vaccination rates of SNF personnel; 2) Recommends a blended approach to improving equity in SNF care; 3) Urges expansion of value-based payment for SNF care; and 4) Encourages CMS to incorporate ANA’s core staffing principles in CMS’ development of minimum staffing levels for nursing facilities.
The Centers for Medicare & Medicaid Services released the FY 2023 Inpatient Psychiatric Facilities (IPFs) Prospective Payment System and Quality Reporting Updates proposed rule. As the agency considers what provisions to finalize, ANA provided comments detailing how CMS should work closely with nurses to address health care equity in IPFs and the larger health care delivery system.
The Centers for Medicare & Medicaid Services Inpatient Rehabilitation Facility (IRF) Prospective Payment System for Federal Fiscal Year 2023 and Updates to the IRF Quality Reporting Program proposed rule. As the agency considers what provisions to finalize, ANA provided comments detailing how CMS should work closely with nurses to address health care equity in IRFs and the larger health care delivery system.
The Centers for Disease Control and Prevention (CDC) released the draft 2022 CDC Clinical Practice Guideline for Prescribing Opioids. As the agency finalizes the draft guideline, ANA urged the CDC to include all providers involved in pain care management, especially nurses, in provider definitions and to promote data and practices to address and overcome barriers in pain management care.
2021
ANA Advises NIOSH on Interventions to Support Nurses’ Mental Health and Well-Being
In a Federal Register notice published on September 27, 2021, the National Institute for Occupational Safety and Health (NIOSH) invited public input on workplace interventions to prevent work-associated stress and foster positive mental health and well-being among health care personnel. In comments, ANA provided highlights of relevant ANA Enterprise (ANAE) research on nurses’ well-being, and summarized the mental health resources that ANAE has developed for the nursing community.
On November 5, 2021, the American Nurses Association issued a response to the Department of Health and Human Services (HHS)'s draft Strategic Plan FY 2022-2026. ANA broadly supports the overall goals laid out in the plan and applauds its commitment to “address long-standing barriers to strengthening the health workforce.”
The Centers for Medicare & Medicaid Services (CMS) released the CY 2022 Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule in July. As the agency considers what provisions to finalize, ANA provided comments urging the agency not to finalize reporting requirements pertaining to vaccinations among health care personnel, detailed how CMS should work closely with nurses to address health care equity, continue to preserve telehealth flexibilities, and reflect the value of nursing services in a new payment system for rural emergency hospitals.
ANA Comments on Proposed CY2022 Medicare Physician Fee Schedule Rule
In a Federal Register notice published on July 23, 2021, the Centers for Medicare and Medicaid Services (CMS) requested comments on proposed rule CY 2022 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Provider Enrollment Regulation Updates; Provider and Supplier Prepayment and Post-Payment Medical Review Requirements
In comments, ANA urges CMS to expand telehealth coverage with specific policies following the Public Health Emergency, and comments on several additional provisions in the proposed rule.
ANA Comments on OSHA Emergency Temporary Standard on Occupational Exposure to COVID-19
In a Federal Register notice published on June 21, 2021, the Occupational Safety and Health Administration released an Emergency Temporary Standard (ETS) on Occupational Exposure to COVID-19 as an Interim Final Rule with comment period. ANA’s comment letter supports the ETS overall, but urges revisions to the ETS to ensure safety for all healthcare personnel providing care during the coronavirus pandemic. In addition, our comments urge OSHA to support strong oversight and enforcement, and to promulgate a permanent standard to protect healthcare personnel from infectious disease.
ANA Letter to ONDCP in Response to Call for Comment on 2022 Strategic Plan
ANA provided comment on the strategic plan for the Office of National Drug Control Policy for 2022, urging support for expanding access to evidence-based treatment through nurse-led programs; advance racial equity issues related to drug policy; and investment in the public health infrastructure.
In a Federal Register notice published on May 14, 2021, the National Institutes for Occupational Safety and Health invited comments on its proposed collection of information to evaluate the agency’s online training resources for nurses to improve sleep and reduce fatigue. ANA’s comment letter supports the proposed evaluation, and recommends that NIOSH include questions on health care employer practices to reduce nurse fatigue from long shift work and overtime, as well as training for nurses.
The Centers for Medicare & Medicaid Services released the FY 2022 Inpatient Psychiatric Facilities (IPFs) Prospective Payment System and Quality Reporting Updates proposed rule. As the agency considers what provisions to finalize, ANA provided comments urging the agency not to finalize reporting requirements pertaining to vaccinations among health care personnel. The comments also detail how CMS should work closely with nurses to address health care equity in IPFs and the larger health care delivery system.
The Centers for Medicare & Medicaid Services Inpatient Rehabilitation Facility (IRF) Prospective Payment System for Federal Fiscal Year 2022 and Updates to the IRF Quality Reporting Program proposed rule. As the agency considers what provisions to finalize, ANA provided comments urging the agency not to finalize reporting requirements pertaining to vaccinations among health care personnel. The comments also detail how CMS should work closely with nurses to address health care equity in IRFs and the larger health care delivery system.
ANA letter to CMS in response to Medicare’s Proposed 2022 Hospice Wage Index and Payment Rate Update
In a Federal Register noticed dated April 14, 2021, CMS published a notice of proposed rule making, Medicare Program; FY 2022 Hospice Wage Index and Payment Rate Update, Hospice Conditions of Participation Updates, Hospice and Home Health Quality Reporting Program Requirements. ANA’s comment letter urges CMS to support comprehensive and actionable reporting of health disparities for the QRP and recommends CMS include nurses’ perspectives to develop relevant data elements.
ANA Letter to CMS in Response to Medicare’s Proposed 2022 Payment Rule for SNFs
In a Federal Register notice published on April 15, 2021, the Centers for Medicare and Medicaid Services requested comments on its proposed 2022 payment rule for Skilled Nursing Facilities (SNFs). ANA’s comment letter 1) Opposes the proposal to collect and publish metrics on COVID-19 vaccination of SNF staff for the purposes of 2023 quality ratings; and 2) Recommends steps CMS can take to engage nurses in Medicare efforts to achieve health equity.
In a Federal Register noticed dated April 15, 2021, the Department of Health and Human Services published a Notice of Proposed Rulemaking (NPRM), Ensuring Access to Equitable, Affordable, Client-Centered, Quality Family Planning Services. The NPRM would restore Title X regulations to the final rule of 2000, with some modifications. In comments, ANA supports the proposal generally, and recommends additional modifications to elevate and clarify nursing rules in providing Title X care.
Dr. Murthy was recently confirmed as the 21st Surgeon General of the United States. ANA congratulated and outlined public health issues that ANA stands ready to address and partner with Dr. Murthy and his office. Those issues include the ongoing COVID-19 pandemic, behavioral health, substance and opioid use disorder, and tobacco cessation.
The National Institute of Nursing Research (NINR) is the process of developing its 2022-2026 strategic plan and is soliciting feedback from the public. In its comments, ANA urged NINR to focus on health equity, evidence-based research, future of the profession, preparedness and mental health, technology, and payment parity as areas of research. ANA noted in its comment letter that it looks forward to future opportunities to engage in this process, as NINR's research is critical to furthering the nursing profession.
In a Federal Register noticed dated November 12, 2020, the Department of Veterans Affair (VA) published an interim final rule (IFR) with comment period Authority of VA Professionals To Practice Health Care. The IFR cites and affirms the authority of the Department of Veterans Affairs (VA) to allow nurses and other professionals to provide care in a state other than the state where they are licensed. The rule also gives notice of the VA’s intention to develop national practice standards for health care delivered in all VA facilities. In comments, ANA generally supports the rule, while asking for greater clarity on implementation issues, such as implications for individual nurses when a state interpretation differs from that of the VA. ANA also emphasizes the need for the VA to engage stakeholders in development of national practice standards.
The Medicaid and CHIP Payment and Access Commission (MACPAC) recently focused its work on maternal and infant health. That work resulted in recommendations for Medicaid to provide 12-months postpartum coverage for eligible beneficiaries, with a 100 percent federal match. In its letter, ANA applauds the Commission for their work on this important issue, while urging them to continue to focus on other aspects of maternal and infant health. Specifically, the letter asks for MACPAC recommendations around full practice authority for Certified Nurse Midwives and Nurse Practitioners, account for nurses in Medicaid payment models targeting women's, maternal, and infant health, and reimbursement for telehealth services.
The Office for Civil Rights at the Department of Health and Human Services sought public comment on proposed modifications to privacy regulations to support and facilitate better coordinated care and patient access to health information. ANA’s comment letter expressed support for the agency’s review of HIPAA privacy and security regulations to enable better care coordination and urged the agency to finalize proposed provisions related to electronic health records that will allow for greater patient access and control of their health information. ANA also expressed concern about certain provisions and urged the agency to carefully consider proposed expansion of disclosure standards and refrain from finalizing the proposed elimination of written acknowledgement of a provider’s privacy practices.
2020
In a Federal Register Notice public on August 4, 2020, CMS requested comments on a proposed rule entitled "Medicare Program; CY 2021 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Medicaid Promoting Interoperability Program Requirements for Eligible Professionals; Quality Payment Program; Coverage of Opioid Use Disorder Services Furnished by Opioid Treatment Programs; Medicare Enrollment of Opioid Treatment Programs; Electronic Prescribing for Controlled Substances for a Covered Part D Drug Under a Prescription Drug Plan or an MA–PD Plan; Payment for Office/Outpatient Evaluation and Management Services; Hospital IQR Program; Establish New Code Categories; and Medicare Diabetes Prevention Program (MDPP) Expanded Model Emergency Policy
https://www.govinfo.gov/content/pkg/FR-2020-08-17/pdf/2020-17127.pdf
ANA in its comments encourages CMS to make permanent reimbursement for audio-only technologies following the Public Health Emergency, expand the definition of treatment services for opioid use disorder to include opioid antagonist medications, and permanently remove federal barriers to Advanced Practice Registered Nurse (APRN) practice that go beyond state regulation, specifically supervision requirements in diagnostic testing.
In a Federal Register Notice published on June 1, 2020, CMS requested comments on a proposed rule entitlted "Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the LongTerm Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2021 Rates; Quality Reporting and Medicare and Medicaid Promoting Interoperability Programs Requirements for Eligible Hospitals and Critical Access Hospitals."
ANA's comment letter urges CMS to: recognize the importance of appropriate nurse staffing levels; support proposed changes to the Medicare and Medicaid Promoting Interoperability Programs; and support continued inclusion of patient safety measures in teh PCH Quality Reporting Program.
On February 12, 2020, the Centers for Medicare and Medicaid Services (CMS) sought public comment on opportunities to improve care, quality and outcomes for women and infants in rural communities. ANA submitted a response urging CMS strengthen roles for nurses and support nurse-led models in programs to improve maternal health care delivery in rural areas. Comments also suggested CMS leverage Medicaid initiatives to incentivize states to expand practice authority for advanced practice registered nurses such as certified nurse midwives and nurse practitioners.
Letter from ANA to Senate Finance Committee in response to the Committee’s request for information on improving maternal health. March 24, 2020
The American Nurses Association (ANA) is pleased to submit comments in response to the Committee’s request for information on improving maternal health. At this moment when the nation is focused on the COVID-19 pandemic, we are all reminded that Medicaid plays a critical role in meeting the needs of our citizens when they are vulnerable. Time and again, states and communities rely on Medicaid’s federal-state partnership to address the most challenging of health and health care issues facing low-income populations. The maternal health crisis is one such challenge, and the crisis has some of its deepest and most devastating impacts on Medicaid populations. Therefore, the Committee has a critical role to play to improve maternal health and deliver better outcomes for Medicaid enrollees.
In a Federal Register notice dated February 18, 2020, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule for policy and technical changes to the Medicare Advantage (MA) program for contract years 2021 and 2022. In the proposed rule, CMS invited input on steps the agency can take to expand access to MA plans in rural areas. In comments, ANA recommended that CMS consider rule changes and subregulatory guidance to encourage MA plans to contract with more advanced practice registered nurses (APRNs), for instance by removing burdensome supervision requirements, and developing new network adequacy standards and review processes.
In a Federal Register notice dated January 17, 2020, the Department of Health and Human Services (HHS) proposed a number of changes to 45 CFR Part 87, Equal Treatment for Faith-Based Organizations, in order to extend additional protections to religious organizations that provide social services under HHS social services grants. ANA commented that the proposed rule could reduce access to HHS services while potentially placing nurses in untenable ethical positions. Specifically, ANA urged HHS not to eliminate the requirement for faith-based grantees to “undertake reasonable efforts to identify and refer the beneficiary to an alternative provider” in cases where the beneficiary objects to the religious character of an organization. ANA cited the Code of Ethics for Nurses which requires nurses making conscience-based care refusals to arrange accommodations to meet patient needs.
On December 26, 2019, the Centers for Medicare and Medicaid Services (CMS) invited public input concerning implementation of the President’s October 3, 2019, Executive Order on Protecting and Improving Medicare for Our Nation’s Seniors. CMS specifically sought suggestions for eliminating unnecessary regulatory burdens on advanced practice registered nurses (APRNs). In response, ANA identified a number of specific Medicare requirements that restrict APRN practice, and expressed strong support for regulatory reform in this area. The letter further urged CMS to purse collaborative solutions with Congress in order to expand access to APRN care in Medicare.
Federal Sign-Ons
The American Nurses Association works with numerous health care stakeholders and organizational affiliates to best elevate the nursing profession. As part of this collaboration with external partners, letters are often developed to help build coalitions and amplify ANA's voice on a range of nursing issues. Below, you can read letters ANA signed onto addressing everything from appropriations to maternal health.
2024 ANA Sign-On Letters
On November 20, ANA and 44 nursing organizations sent a letter to congressional leadership urging Congress not to enact any legislation that would overturn the Centers for Medicare and Medicaid Services' minimum staffing standards for long-term care facilities final rule.
ANA Signs on to Letter Supporting Midwifery Education Programs
On April 1, ANA joined on to a letter urging Congress to maintain funding levels for accredited midwifery education programs in Fiscal Year 2025.
ANA Signs on to Letter Supporting Funding for Child Health and Human Development Research
On April 1, ANA joined Friends of NICHD members on a letter requesting an increase in funding for the Eunice Kennedy Shriver National Institute of Child Health and Human Development (NICHD) in Fiscal Year 2025.
ANA Signs on to Letter Supporting National Institutes of Health Funding
In March, ANA signed on to an Ad Hoc Group for Medical Research letter recommending an increase in funding for the National Institutes of Health (NIH) in Fiscal Year 2025.
ANA Signs on to Letter Supporting Access to Telehealth
On February 22, ANA signed on to an Alliance for Connected Care letter urging Congress to permanently extend telehealth flexibilities ahead of the December 31, 2024 deadline.
ANA Signs on to Letter Supporting the Dr. Lorna Breen Reauthorization Act
On February 15, ANA signed on to a letter thanking Senators Tim Kaine (D-VA) and Todd Young (R-IN), and Representatives Susan Wild (D-PA), Jen Kiggans (R-VA), Debbie Dingell (D-MI), and Buddy Carter (R-GA) for championing legislation to reauthorize the Dr. Lorna Breen Health Care Provider Protection Act. This law increases access to mental health care for health care providers.
ANA Signs on to Letter Urging Congress to reauthorize the SUPPORT Act
On February 9, ANA signed on to a Mental Health Liaison Group coalition letter in support of legislation to reauthorize the Substance Use Disorder Prevention That Promotes Opioid Recovery and Treatment for Patients and Communities (SUPPORT) Act. This law makes investments to treat substance use disorders and co-occurring mental health conditions.
ANA Signs on to Letter Urging EPA to Finalize Lead and Copper Rule
On February 5, ANA joined Alliance of Nurses for Healthy Environments members on a letter urging the Environmental Protection Agency to finalize their Lead and Copper Rule without delay. The letter provided comments on how to improve the rule to ensure our communities have access to safe drinking water.
ANA Signs on to Letter Supporting the Healthy Start Program
On January 18, ANA signed on to a letter urging Congress to combat the ongoing maternal and infant health crisis by funding the Healthy Start program.
ANA Signs on to Letter Supporting the PREEMIE and Preventing Maternal Deaths Reauthorization Acts
On January 17, ANA and its health care partners issued a letter to congressional leaders urging Congress to include the PREEMIE Reauthorization Act and Preventing Maternal Deaths Reauthorization Act in the final Fiscal Year 2024 appropriations package.
ANA Signs on to Letter Rejecting Non-Defense Cuts to Spending for FY 2024
On January 8, ANA signed on to a letter alongside over 1,100 organizations rejecting cuts to non-defense discretionary spending for Fiscal Year 2024 and calling for continued investment in public health and other healthcare services.