AAPA Asks CMS to Remove Regulatory Restrictions on PAs Providing Hospice Care

In response to CMS’ annual proposed rules, AAPA offered suggestions for making care more efficient in Skilled Nursing Facilities and Inpatient Rehabilitation Facilities.

July 9, 2025

By Trevor Simon, MPP, Senior Director, Regulatory Policy

In June 2025, AAPA submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding the topics of hospice, skilled nursing facilities, inpatient rehabilitation facilities, and inpatient psychiatric facilities. These comments, in response to annually released proposed rules that make adjustments to the hospice wage index and respective fee schedules, responded directly to inquiries made within the rules, as well as identified policy obstacles faced by PAs in these settings. Below is a brief summary of the topics AAPA discussed in each, with links to the full letters.

2026 Hospice Wage Index
In AAPA’s comments to the proposed rule, we advocated for removing barriers to efficient care, including regulatory restrictions on PAs employed by a hospice ordering medications and acting as an attending physician. AAPA also encouraged joint efforts with Congress to address statutory restrictions on PAs certifying terminal illness, conducting the face-to-face visit prior to recertification, and participating in the same role as physicians in an interdisciplinary group. Finally, AAPA commented on the concepts of interoperability, nutrition, and well-being that CMS proposed for inclusion in future years of the hospice quality reporting program.

2026 Skilled Nursing Facilities (SNF) Prospective Payment System
In AAPA’s response to the proposed rule, we provided comments on several proposed policies that seek to streamline and simplify processes, including a reduction in the data submission timeline for the quality reporting program, the removal of Social Determinants of Health data elements, and the removal of the Health Equity Adjustment. AAPA provided suggestions for CMS to maximize the efficiency of care provided in SNFs by removing regulatory requirements that certain visits in these settings can only be provided by a physician. Finally, AAPA commented on the concepts of interoperability, nutrition, well-being, and delirium that CMS proposed for inclusion in future years of the SNF quality reporting program.

2026 Inpatient Rehabilitation Facilities (IRF) Prospective Payment System
In AAPA’s response to the proposed rule, we provided comments on several proposed policies that seek to streamline and simplify processes, including a reduction in the data submission timeline for the quality reporting program and the removal of Social Determinants of Health data elements. AAPA provided suggestions for CMS to maximize the efficiency of care provided in IRFs by removing regulatory requirements that only a rehabilitation physician can provide certain visits in these settings. AAPA also commented on the measure concepts of interoperability, nutrition, well-being, and delirium, proposed by CMS for inclusion in future years of the IRF quality reporting program.

2026 Inpatient Psychiatric Facilities (IPF) Prospective Payment System
In AAPA’s comments to the proposed rule, we emphasized the importance of PA contribution to behavioral health and the competencies PAs possess to help meet increasing demand for these services. AAPA advocated for CMS to work with Congress to authorize PAs to certify and recertify need for inpatient psychiatric care, requested revision of CMS guidance to clarify that psychiatric assessments may be conducted by PAs, and cautioned against the removal of screenings for Social Determinants of Health under the IPF quality reporting program.

For more of AAPA’s comments to CMS and other federal agencies, visit our Communications with the Federal Executive Branch webpage.

If you have any questions regarding AAPA’s comments, please contact [email protected].

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