APN prescriptive authority barriers.
The initial number of APNs that received a notification that their authority was rescinded was approximately 300. There are approximately 2400 prescribing APNs in Colorado, thus this represented around 12.5% of prescribing APNs. These APNs were APNs with existing prescriptive authority under the new rules enacted under Sunset of the Nurse Practice Act in 2009. They represent experienced providers with a history of prescribing for many years.
Colorado Nurses Association had played a lead role in the Nurse Practice Act legislation and also in the development and negotiations around the alternate model for prescriptive authority which was adopted. The move away from collaborative agreements to the articulated plan model was proposed through negotiations between Colorado Nurses Association and Colorado Medical Society, and was later enacted in legislation. "Grandfathering" was a key provision in the NPA statute that the association supported-in other words, having a provision that those with existing prescriptive authority at the time would not have imposition of newer requirements intended for new entrants to prescribing (preceptorships, mentorships as examples).
The requirement for those with existing prescriptive authority stated that those APNs had to submit an attestation (NOT THEIR ARTICULATED PLAN) by a date deadline (July 1, 2011). Obviously, there were a high percentage that did not meet the requirement, despite many who did. The association committed to finding out more about the reasons around the issue.
Assisting CNA in gathering information about the issues, the Certified Nurse Midwives surveyed members of their association. I met with several APNs directly affected at the CNA offices. Meetings were conducted between CNA and DORA to discuss concerns. Representative Deb Gardner (who is no longer in the legislature) had been contacted by APNs and was an early champion for seeking a resolution for APNs. CNA met with Representative Gardner over the summer. Immediately prior to the current session, members of the Government Affairs and Public Policy Committee (GAPP) of CNA-conducted phone surveys of some of the APNs affected.
The following issues were identified through the outreach efforts. There were issues around notification. There had been a one time written notification to the prescribing APNs-approximately a year ahead of the date for submission. Some APNs stated they had not received any notification. Despite the fact that DORA, CNA, NPATCH (Nurse Physician Advisory Task Force), and others had tried to disseminate broadly regarding the deadline through a website link, outreach presentations, etc.-some did not know about the deadline. The listing of the 300 APNs affected includes broad distribution from all areas of the state.
It is important to remember that the prior system for prescriptive authority had existed without change for approximately 15 years. The newer requirements for prescriptive authority for APNs enacted during the Nurse Practice Act (2009)-were distinct and unique to our state. The requirements for articulated plans, preceptorships, mentorships, etc-are fairly complex to understand in their entirety. It is a new transitional model for prescriptive authority. While many efforts were made to communicate changes, an unintended consequence may have resulted. We need APN providers and prescribers-and value the experienced APNs that have been prescribing for many years.
Some APNS had challenges in administrative support from the Department of Regulatory Agencies. Some of the complaints cited included not being able to get information, inconsistent information, lost paperwork and applications by the agency, repetitive requests for additional information, etc.
There was a lack of understanding by some regarding the requirements-including the requirement for physician signatures for the articulated plan. There were concerted agreements between CNA and Colorado Medical Society-that there would be support provided to APNs that communicated they were having challenges finding a physician for signature of their plans. NPATCH also had discussed support for this issue in prior meetings. Were APNs aware that there could be assistance on this?
Several APNs were confused by employers-that had collected their paperwork, thus creating misunderstanding regarding who was ultimately responsible for the submission. There are APNs that have lost their positions because of the loss of PA. For others-this has impacted their work operations and the physicians and facilities where they work. Within the 300 APNs-there were APNs that had consciously made the decision to either retire or that had moved to another state-a logical exception to any issues.
There is acknowledgement that some were aware of the deadline, but had not met the requirement. It is a professional responsibility to comply. I will note that in some of these cases, there were extentuating personal circumstances. This is not a justification or an excuse, but I do support that APNs are professionals and as such do want to comply with regulatory requirements.
CNA is proposing that there should be a short time frame extention for APNs (WITH EXISTING PRESCRIPTIVE AUTHORITY PRIOR TO JULY 1, 2010) that have had their authority rescinded (the 300 originally notified) to submit attestations. There are APNS that may have had some processing by the Board on this current issue, but may also have had to complete requirements that were never intended for those that had existing prescriptive authority as stated (example-going back to school, mentorship hourse, etc).
There is a legislative bill in the current Colorado session to try and address these concerns. HB 12-1065 has been introduced in the House and has at the time of this writing-passed out of the House Health and Environment Committee. The sponsor is Representative Pete Lee. Colorado Nurses Association is actively supporting this bill effort. The association also continues to work in collaboration with DORA to try and facilitate solutions for the APNs affected. CNA would also acknowledge former legislator Anne McGihon for support in the legislative effort to help the APNs affected. Please refer to the next Colorado Nurse edition for further information on the bill's progress. Colorado Nurses Association thanks Rep Deb Gardner for her early work on this issue. Acknowledgement is also extended to House Health and Environment Chair, Ken Summers (bill Co-Sponsor) for support on this issue.
Fran Ricker, RN, MSN
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|Title Annotation:||Executive Director's Column|
|Date:||Feb 1, 2012|
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