AAPA’s Letters to HHS, CMS, FDA, and OMB Recommend Changes to Multiple Federal Regulations and Policies

AAPA calls for the removal of policies that limit Medicare coverage and hinder PAs in disaster response.

July 9, 2025

By Sondra DePalma, Vice President, Reimbursement and Professional Practice

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.

AAPA recommended that the agencies rescind or revise barriers to PA practice that are not based on statute, increase costs, threaten Medicare program integrity, harm national interest, impede disaster response, create inefficiency, and impose administrative burdens. Below are brief examples of some of the recommendations AAPA provided.

Authorize PAs to Provide the Services They Are State Licensed to Provide
AAPA identified regulations and policies that limit Medicare coverage of services that federal and state laws authorize PAs to perform. Various limitations on Medicare coverage in Skilled Nursing Facilities, Inpatient Rehabilitation Facilities, Ambulatory Surgical Centers, hospice, and other settings contradict the statutory authority for PAs to provide “physicians’ services” they are authorized to perform by their state license. These unfounded limitations require a physician to provide services that PAs are qualified to provide, creating inefficiency, decreasing access to needed care, and exacerbating the effects of workforce shortages.

Increase Access to Preventive Services and Chronic Disease Management
AAPA noted opportunities for CMS to improve access to preventive services and chronic disease management by removing barriers for PAs and their patients. For example, Medicare policies and Coverage Determinations that require physician certifications for some home glucose monitors and scheduled ambulance transports, limitations on who can order and perform colorectal cancer screenings, and other arbitrary restrictions limit access to preventive, cost-saving services.

Reduce Administrative Burdens
AAPA recommended that CMS remove unnecessary administrative requirements that are burdensome to PAs and physicians. For example, physician certification requirements for specific services and physician co-signature requirements, particularly in Critical Access Hospitals, impose burdens, often in underserved areas. These arbitrary administrative requirements can decrease access, reduce efficiency, and increase costs without benefiting patients.

Improve Disaster Response Capabilities
AAPA suggested revisions to regulations to improve PAs’ ability to respond to disasters. Specifically, the reinstatement of CMS requirements that had been waived during the COVID-19 public health emergency and FDA requirements for the emergency release of blood products limit the efficiency and flexibility needed most in critical situations.

AAPA’s Reimbursement and Professional Advocacy staff will continue to advocate for PAs to ensure they are authorized to provide the high-quality care they are trained and qualified to provide.

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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