CMS PA Student Documentation — What’s New?

PAEA’s Government Relations team has been working diligently on the CMS student documentation issue, which has exacerbated the clinical site shortage for programs across the country. Since the October Networker update, PAEA has continued its work with an interprofessional group that includes advanced practice nursing organizations, family medicine associations, and AAPA.

We have met with CMS officials and solicited letters of support from Health Resources and Services Administration (HRSA) advisory committees. These committees advise the HRSA Administrator and address primary care, nursing, and interprofessional and community-based linkages. Their letters, sent to HHS Secretary Alex Azar, CMS Administrator Seema Verma, and Congressional chairs and ranking members of Committees of Jurisdiction, can be found here:

In December, PAEA and the interprofessional group met with Elinor Hiller, Administrator Seema Verma’s legislative advisor for Medicare in Washington, DC. This productive meeting directed the attention of senior leaders within CMS to the critical problems caused by the documentation issue for all advanced practice clinicians and their preceptors. The group followed up with CMS officials in Baltimore in early February to tackle both the issue of PA/APRN student documentation for physician preceptors and the recognition of PA preceptors as “teaching clinicians.”

PA/APRN Student Documentation

The group believes the student documentation issue can be addressed through guidance whereby CMS could interpret the word “student” to include PA/APRN students. This would not require a rule change and would be consistent with the existing CMS definition of “student.”

APRN/PA Preceptors

There are two ways to ensure these documentation changes are applied to APRN/PA preceptors through guidance. CMS would need to issue moderate refinements to already implemented policies to directly align the requirements for APRN/PA preceptors and their students with teaching physicians and medical students in outpatient and inpatient settings.

If CMS determines that a rule change beyond guidance is necessary, they can include PA and APRN preceptors in the definition of “teaching physician.” It is the group’s stance that the Secretary has the explicit statutory authority to define “teaching physician” and can define it to include PA/APRN preceptors. The group is recommending that the Secretary use the phrase “teaching clinician,” which is a more inclusive term that recognizes the role of other providers in training the health care workforce.

If CMS believes that this change must be done through rule change, the Secretary can use his authority to immediately issue an enforcement instruction to Medicare Administrative Contractors (MACs). MACs could be instructed to allow the same documentation requirements for PA/APRN preceptors submitting evaluation/management claims as they would for teaching physicians until rulemaking is completed. This instruction would reduce the teaching physician burden for PA/APRN preceptors to ensure there are no further disparities in clinical training opportunities.

PAEA’s leadership has demonstrated its commitment to ensuring this work is advanced until a solution is reached, and the GR team will keep our members appraised of ongoing developments.