AAPA Shines Light on Barriers to PA Practice and Opportunities to Improve Care in Multiple Comment Letters to Agencies

July 9, 2025

Over the last several weeks, AAPA submitted a series of comments to multiple agencies addressing topics ranging from anticompetitive practices against PAs to opportunities to improve policies in skilled nursing facilities, inpatient rehabilitation facilities, inpatient psychiatric facilities, and hospice. In addition, AAPA raised attention to regulatory and policy barriers that limit PA practice and impose administrative burdens in letters to HHS, CMS, FDA, and OMB.

AAPA will continue to advocate for PAs to ensure they are authorized to provide the high-quality care they are trained and qualified to provide and encourages PAs to contact AAPA’s Reimbursement and Professional Advocacy team  with questions regarding AAPA’s comments.

Comments to DOH and FTC
In May 2025, AAPA submitted comments to the Department of Justice (DOJ) and the Federal Trade Commission (FTC) in response to separate, but similar, requests for information (RFIs) regarding the topic of anticompetitive laws and regulations at both the state and federal levels. The impetus for the DOJ’s RFI was the launch of a new DOJ task force – the Anticompetitive Regulations Task Force. Read more.

CMS Annual Proposed Rules
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. Read more.

Comments to HHS, CMS, FDA, and OMB
From May to July 2025, AAPA submitted comments to the Department of Health and Human Services (HHS), Centers for Medicare and Medicaid Services (CMS), Food and Drug Administration (FDA), and Office of Management and Budget (OMB) on ways to remove barriers to cost-effective, efficient, and high-quality healthcare that currently exist in federal regulations and policies. Through letters to HHS, CMS, FDA, and OMB, as well as submissions through CMS and OMB portals, AAPA identified numerous regulatory and policy barriers that arbitrarily and unjustifiably limit PA practice and impose administrative burdens. Read more.

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