VA National Standards of Practice: Federal Supremacy Project

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Our nation’s veterans should be provided with physician-led health care teams that consider important scope of practice limitations and make the most of the respective education and training of physicians and non-physician practitioners. However, the National Standards of Practice developed by the VA Federal Supremacy Project would override long-established state laws governing scope of practice and health-professional licensure and negatively impact the quality of care provided to our veterans. Accordingly, the AMA has been working to oppose and shape the implementation of the VA Federal Supremacy Project to ensure that our nation’s veterans are provided with the best care possible. 

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  • On Feb. 21, 2024, the AMA spearheaded a sign-on letter (PDF) urging the Department of Veterans Affairs (VA) to disclose the names of all participants on the 51 National Standards of Practice (NSP) Workgroups and to include unbiased physician representatives on every workgroup. The sign-on letter also urged the VA to halt the development of NSPs that conflict with state law noting that this discrepancy would lead to a confusing mix of standards that are not meaningfully different than the current variability among state scope of practice laws.
  • On Oct. 5, 2023, the AMA sent a letter (PDF) providing comments to the Department of Veterans Affairs (VA) in connection with the National Standards of Practice (NSP) Listening Sessions concerning known state variances for select health care occupations and recommendations on what should be included in the VA’s NSPs. The AMA urged the VA to provide our veterans with the highest possible quality of care and to rescind the implementation of the Federal Supremacy Project or, at a minimum, ensure that physician-led team-based care is maintained and that physician representation be mandatory on all the Work Groups, not just the Physician Work Group.
  • On Sept. 19, 2023, the AMA testified before (PDF) the U.S. House of Representatives Committee on Veterans Affairs Subcommittee on Health as part of a hearing concerning the “VA’s Federal Supremacy Initiative: Putting Veterans First?” Since the Veterans Health Administration is such a large health care system, the actions it takes, especially in terms of the scope of practice of its non-physician providers, could have an immense impact on health care in its entirety. National Standards of Practice developed by the VA Federal Supremacy Project would override long-established state laws governing scope of practice and health-professional licensure, and, as such, the quality of care provided to our veterans, and potentially patients across the nation, will decline if the Project is fully implemented. The AMA therefore opposed the implementation of the Federal Supremacy Project and urged Congress to ensure that physician-led team-based care is maintained and that physician representation on all the Work Groups, not just the Physician Work Group, be mandatory.
  • On July 26, 2023, the AMA sent a letter (PDF) to the VA Assistant Under Secretary for Health for Clinical Services thanking them for our recent meeting and following-up about the Department of Veterans Affairs’ (VA) most recent draft National Standards of Practice (NSP) for Cytotechnologists and Histopathology Technologists. The AMA acknowledged that the VA’s draft Cytotechnologist Standard of Practice was consistent with the Standards and Guidelines for the Accreditation of Educational Programs in Cytology. Furthermore, the VA’s draft Histotechnologist Standard of Practice was consistent with the standards established by the National Accreditation Agency for Clinical Laboratory Sciences. However, even though they do not change the standard of practice, the AMA noted serious concerns about the nomenclature used in both draft NSPs.
  • On April 26, 2023, the AMA submitted a statement (PDF) to the U.S. House of Representatives Veterans Affairs Committee Subcommittee on Health as part of a roundtable concerning the Department of Veterans Affairs (VA) Federal Supremacy Project. The VA Federal Supremacy Project is overriding long-established state laws governing scope of practice and health-professional licensure which will cause the quality of care provided to our veterans to decline if the Project is fully implemented. To that end, the AMA urged Congress to provide our veterans with the highest possible quality of care and to rescind the implementation of the Federal Supremacy Project.
  • On Dec. 16, 2021, the AMA spearheaded a sign-on letter (PDF) outlining ongoing concerns with the Federal Supremacy Project.
  • On July 29, 2021, the AMA spearheaded a sign-on letter (PDF) to the Department of Veterans Affairs (VA) expressing serious concerns with the VA’s efforts to develop National Standards of Practice for physicians and other health professionals that supersede state scope of practice and licensure laws. In particular, the letter noted dismay that the VA did not provide a transparent process by which public stakeholders had an adequate opportunity to review and provide meaningful input into the standards of practice.
  • On Jan. 7, 2021, the AMA led a sign on letter (PDF) in opposition to the Department of Veterans Affairs’ (VA) Interim Final Rule, entitled “Authority of VA Professionals to Practice Health Care,” which would permit virtually all VHA-employed non-physician providers to practice without the clinical supervision of physicians and without regard to state scope of practice law.

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