Scope of Practice

AAPM&R is taking action.

Federal and State Advocacy Actions in 2024:

• Your Academy submitted comments to the Washington Department of Health (WA DOH) advocating against a proposal to expand the scope of practice for naturopaths. The expansion would allow naturopaths to complete minor office procedures and open the door for them to perform surgery. Dr. Richard Chang, Chair of the State Advocacy Committee (SAC2), warned of the negative impact such an expansion could have on patients in Washington.   
• Your Academy shared concerns directly with the Medical Society of the State of New York on NY Senate Bill 3361 which proposed removing limits on physical therapists treating patients without referral from a physician. NY Senate Bill 3361 failed to advance in the 2023-2024 legislative session.
• Your Academy joined a coalition letter to Congress led by the American Medical Association (AMA) opposing the Equitable Community Access to Pharmacist Services Act (H.R. 1770/S. 2477), federal legislation that would inappropriately allow pharmacists to perform services that would otherwise be covered if they had been furnished by a physician, test and treat patients for certain illnesses, and expand Medicare payment for pharmacists.
• Your Academy, in collaboration with the American Medical Association’s Scope of Practice Partnership (AMA SOPP) and the New Hampshire Medical Society (NHMS), engaged with members in New Hampshire to oppose HB 1222. If passed, this legislation would allow physician assistants to practice medicine without any physician involvement by removing the current collaboration requirements.
• Your Academy notified members in Missouri to a scope of practice expansion effort by the orthotists or prosthetists in their state. Missouri HB 2115 would allow orthotists or prosthetists to evaluate and initiate treatment for patients without referral from a physician. Your Academy shared our significant concerns about this proposal with the Missouri State Medical Association and the AMA. The bill failed to pass during this legislative session.
• Your Academy joined a coalition of physician membership societies to send a letter to the U.S. Department of Veterans Affairs (VA) urging the VA to not adopt new national standards of practice that would inappropriately expand scope of practice for non-physician providers. The VA is currently engaged in a long-term project, the Federal Supremacy Project, that is evaluating national standards of practice for all types of healthcare providers employed by the VA.

• Your Academy submitted a joint statement with the American Association of Neuromuscular & Electrodiagnostic Medicine (AANEM) affirming the necessity of physician supervision for these medical services in response to a draft coverage policy proposal that recommended expanding the scope of practice for non-physician providers for intraoperative neurophysiological monitoring services.
• Your Academy sent a joint letter to CMS reiterating our position that medical necessity reviewers must have expertise in the field of medicine that is appropriate for the item or service being requested before a plan can issue an adverse decision, particularly in the IRF setting.
• Your Academy launched an ongoing federal grassroots campaign to contact members of Congress and express opposition to H.R. 2713, the Improving Care and Access to Nurses (ICAN) Act. This legislation would inappropriately expand scope of practice for non-physician practitioners including nurse practitioners, certified nurse midwives, certified registered nurse anesthetists, clinical nurse specialists and physician assistants. 
• Your Academy joined the American Medical Association (AMA) and more than ninety medical societies and associations in submitting a letter to congressional leadership in opposition to H.R. 2713 which proposed expanding scope of practice to nonphysician practitioners, including nurse practitioners, certified nurse midwives, certified registered nurse anesthetists, clinical nurse specialists, and physician assistants.
• Your Academy organized an ongoing Federal grassroots campaign to contact members of Congress and express opposition to S. 131/H.R. 618. Academy members responded strongly to this campaign, sending more than 560 letters to Congress to stop the expansion of scope of practice for nurse practitioners and physician assistants under the federal Worker’s Compensation Program.
• Your Academy launched a grassroots campaign for Academy members in New York to stop the elimination of oversight of physician assistants in Part W of the Governor’s proposed Health and Mental Hygiene Budget (A.3007/S.4007). Academy members sent more than 80 letters to state officials in this ultimately successful advocacy effort. The final budget was signed by the Governor on May 3 and the provision eliminating the oversight of physician assistants was removed.

AAPM&R's Scope of Practice Workgroup

Recognizing the growing concern of non-physician (and non-PM&R) scope of practice expansion, your Academy is addressing this issue through multiple committees, including a Scope of Practice Workgroup. This workgroup is comprised of representatives from the Health Policy, Practice, and Advocacy (HPPA) Committee, the Health Policy and Legislation (HP&L) Committee, and the Reimbursement and Policy Review Committee (RPRC), and AAPM&R’s representative to the AMA Scope of Practice Partnership (SOPP).

Scope of Practice Partnership with the American Medical Association (AMA)

Your Academy, as a member of the AMA Scope of Practice Partnership (SOPP), actively engages in the collaborative effort of the AMA, American Osteopathic Association (AOA), national medical societies, state medical associations and state osteopathic medical associations to oppose scope of practice expansions by non-physician providers that threaten the health and safety of patients. The SOPP achieves this goal through legislative activities, regulatory activities, judicial advocacy, and programs of information, research and education. Active participation in this collaborative ensures physiatry is represented and contributes to SOPP’s goal to protect the health and safety of patients whose well-being may be threatened by health care practitioners who lack the education, training or experience to perform procedures for which they seek licensure or recognition.