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

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 Asks CMS to Remove Regulatory Restrictions on PAs Providing Care in Hospice and Facilities

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.

AAPA Submits Comments to DOJ and FTC Underscoring Anticompetitive Regulations Placing Barriers to PA Practice

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. These comments directly addressed inquiries made within the RFIs and identified obstacles faced by PAs due to anticompetitive measures.

AAPA Responds to Expiration of CMS Public Health Emergency

The public health emergency (PHE) declaration, put in place by the federal government during the COVID-19 pandemic, temporarily lifted several outdated policies that prevented PAs from practicing to the full extent of their education and experience. In a letter to CMS Administrator Chiquita Brooks-LaSure, AAPA requested that certain PHE policies become permanent and others be discontinued or amended.

What PAs Should Know About the 2023 Physician Fee Schedule Rule

On November 2, the Centers for Medicare and Medicaid Services (CMS), the federal agency that oversees the Medicare program, released the 2023 Physician Fee Schedule (PFS) final rule. The rule updates numerous Medicare coverage and payment policies that impact PAs, physicians, and other health professionals.
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CMS Mandatory Reporting Program to Include Data on PAs

In 2022, PAs are required to be included in the Centers for Medicare and Medicaid Services (CMS) Open Payments program. Open Payments is a national disclosure database aimed at improving transparency regarding healthcare financial relationships on a public website.
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AAPA Shares Update on State Medicaid Policies Pertaining to PAs

AAPA periodically issues a questionnaire to Medicaid agencies in all 50 states and D.C. to clarify policies pertaining to PAs. This year more states say they enroll PAs as billing providers – indicating that PAs are authorized to receive direct payment.
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CMS Releases 2022 Physician Fee Schedule Rule

As part of the final 2022 Physician Fee Schedule, the Centers for Medicare and Medicaid Services (CMS) finalized numerous Medicare coverage and payment policies that directly impact PAs. This is a brief summary of key policy changes which are effective January 1, 2022.