Rassi, Cristin

The proposed rule has neglected to include Certified Clinical Nurse Specialists (CNS) to the language. Clinical Nurse Specialists are Advanced Practice Nurses who provide specialized care to a specific patient population. Many Clinical Nurse Specialists are working in hospitals and order respiratory and rehabilitative services daily. The proposed language should read... "The Centers for Medicare and Medicaid Services (CMS) has proposed changing its regulations to allow PAs [and (APRNs) Advanced Practice Registered Nurses, (CNP-Certified Nurse Practitioner), (CNS-Certified Clinical Nurse Specialist), (CRNA-Certified Registered Nurse Anesthetist), and (CNM-Certified Nurse Midwife) to order respiratory care services without the need for a physician's co-signature. The proposed CMS regulations are part of the FY 2011 Hospital Inpatient Prospective Payment Systems (IPPS) (pages 656-9) that would be effective October 1, 2010. Current regulations state that respiratory care services "must be provided only on, and in accordance with, the orders of a doctor of medicine or osteopathy." CMS interprets that language as allowing PAs [and APRNs- (CNP, CNS, CRNA, CNM)] to order the respiratory care, but requires a physician co-signature. The proposed change also clarifies the ability of PAs [and APRNs-(CNP, CNS, CRNA, CNM)] to order rehabilitation services." Please include all (APRNs), CNS, CRNA, and CNM specialties in the proposed language in addition to CNP. APRNs have been ordering respiratory and rehabilitative services daily while providing safe, quality, efficient, effective, timely care for our patients. In addition to ordering these services, APRNs provide excellent care by reducing patient length of hospitalization, improving patient satisfaction, and enhancing patient outcomes. Thank you for your time, Cristin Rassi, APN, CNS, Neurosurgery Illinois