VA Modifies Rule on Scope of Services for APRNs

By AHRA Staff

In May of 2016, the Department of Veterans Affairs (VA) proposed to amend its regulations to permit full practice authority to all VA advanced practice registered nurses (APRNs). APRNs for the purposes of this rule included Certified Nurse Practitioners (CNPs), Certified Registered Nurse Anesthetist (CRNA), Clinical Nurse Specialist (CNS), and Certified Nurse-Midwives (CNM). This proposal included language allowing a Certified Nurse Practitioner to “order, perform, supervise, and interpret laboratory and imaging studies.”

The AHRA sent comments to the VA expressing concerns with this proposal. While we noted the important role APRNs play in our nation’s healthcare system, we disagreed with the VA’s proposed expansion of APRN scope of services. We argued that the provider producing a medical image must know how to “properly position the patient, properly calibrate the equipment to reflect various factors such as patient age, gender, ethnicity, body density and skin pigmentation…” and that these techniques and skills are not covered by APRN education. Therefore, we argued that “the performance of medical imaging procedures should be exclusively within the scope of practice of Radiologic Technologists, individuals specifically educated to perform medical imaging.”

Likewise, we argued that only certified radiologists were properly educated and trained to interpret advanced medical images across all modalities. We pointed out that even physicians are not qualified to interpret CT or MRI images unless they are certified radiologists and urged the VA to reconsider their proposal.

Thankfully, just a few days ago, the VA decided to modify their proposal based on our comments.

The VA noted as part of their rational for this modification that:

…commenters stated that only trained radiologists, who undergo 10 years of comprehensive training to accurately interpret high-tech imaging exams and safely account for the radiation used in many scans should perform these duties. The commenters further stated that imaging exams should only be performed by registered radiological technologists. The commenters stated that only trained radiologists, who undergo 10 years of comprehensive training to accurately interpret high-tech imaging exams and safely account for the radiation used in many scans should perform these duties. The commenters further stated that imaging exams should only be performed by registered radiologic technologists.

As such the VA’s final rule was amended to make it clear that CNPs are only allowed to “order laboratory and imaging studies and integrate the results into clinical decision making.”

This modification ensures that only radiologic technologists perform imaging services in VA facilities, and only certified radiologists read images in a VA facility. The AHRA regulatory affairs committee is pleased to see the VA acknowledge and address our concerns in this final rule.