We cannot thank each of you enough for your tremendous support and advocacy during the 60-day comment period on VA’s proposed “Advanced Practice Registered Nurses” rule. Together, ASA reached a record level of advocacy for our patients, including Veterans who have earned and deserve access to safe, high-quality anesthesia care.
The Comment Period
Due to overwhelming advocacy, the regulations.gov website has received a total of more than 223,000 comments on the proposed rule, a record number of comments for a proposal in the Department of Veterans Affairs (VA). When the comment period closed, the website reflected 167,000 comments that could be viewed. Since that date, additional copies of hard-copy comments have been periodically posted – some in support of our position, others supporting full practice authority for APRNs or nurse anesthetists.
During the 60-day public comment period, there were over 90,000 comments submitted to the Federal Register expressing support for physician-led anesthesia care for Veterans. Considering the comments specific to the anesthesia section of the rule, there can be no doubt that America has spoken in overwhelming support of physician-led anesthesia care.
Among those comments, approximately 11,200 were sent from Veterans, and an additional 14,600 were from relatives of Veterans. Another 5,000 comments were submitted from Veterans and their family members in support of physician-led anesthesia care in VA as part of ASA’s advocacy efforts during Memorial Day.
We are continuing to count and analyze all comments submitted with a particular focus on those comments that mention the anesthesia provision of the rule.
ASA’s official comment submission detailing patient safety concerns with the proposed rule can be viewed here: https://www.regulations.gov/document?D=VA-2016-VHA-0011-164429
You can read other public comments, and find more information on the proposed rule, here: https://www.regulations.gov/docket?D=VA-2016-VHA-0011
Throughout the comment period, ASA actively engaged with the press to inform the public about the patient safety implications of this proposal. As a result of this effort, there were 400 media outlets that covered this issue, which reached an overall audience of more than 330.5 million people. This press attention was crucial to raising awareness and ensuring our patient safety concerns were represented.
Additionally, we are extremely grateful to our colleagues who wrote letters to the editor to their local papers, explaining why they oppose VA’s proposal to remove physician anesthesiologists from Veterans’ care. Due to overwhelming advocacy, this letter writing campaign resulted in a total of 66 letters to the editor and op-ed placements. On social media, the #SafeVACare hashtag created 13,019,985 online impressions, including 4,278 tweets. Our advocacy was impactful and made an important step towards raising awareness to this campaign on a limited timeline.
Continuing our longstanding strategy, ASA actively engaged in a multi-prong method to engage various stakeholders in the Safe VA Care initiative. Our allies in Congress coordinated a sign-on letter that resulted in 79 signatories, a strong bipartisan statement. Several other members of Congress chose to write individual letters to VA as part of the comment period, or have engaged in various methods. We even saw state officials contact VA to officially register their patient safety concerns. ASA is continuing to grow our support in Congress and will ask members to be active constituents.
Similarly, we continue to build relationships with various organizations that support Veterans. In addition to our longtime allies, we continue to engage with groups so they can learn about VA’s proposal to remove physician anesthesiologists from Veterans’ care teams, emphasizing the fact that this would lower the standard of care for our nation’s Veterans.
While there was much anticipation of the comment period, our work to protect Veterans’ access to safe anesthesia is not over. While VA leadership reviews the public comments submitted before issuing a final rule, we will continue to engage with all of our allies in Congress, Veterans organizations and the community to support the safest, highest quality anesthesia care available and to make certain that Veterans are aware of the impact this proposal could have on their care.
Please stay involved in our advocacy efforts, and be prepared for a future call for action if this issue progresses! We encourage you to join the ASA Grassroots Network, and contact your lawmaker to request a meeting to discuss the importance of physician-led anesthesia.
As ASA continues to review the comments and the advocacy on this issue, please stay aware of future communications and resources. If you have any questions or concerns about the comment period or our next steps, please do not hesitate to reach out to either of us.
Thank you for your continued advocacy and support,
Dan Cole, M.D.
Jeffrey Plagenhoef, M.D.