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Document ID: CMS-2011-0123-0007
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: July 07 2011, at 12:00 AM Eastern Daylight Time
Date Posted: July 21 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: June 17 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: August 16 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80ebc0bf
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This is comment on Proposed Rule

Medicare Program: Conditions of Participation for Community Mental Health Centers

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1. there is a definition of a psychiatric nurse, but there is no definition mention or inclusion of APRN psychiatric nurses. 2. The regs state that the team is led by the Physicians, but does not specify the type of physician, opening the door to untrained individuals who fail at their specialties and have no other option. And there is no mention of the role of the other authorized prescribers, such as psychiatric APRNs' The national stats indicate that there is a shortage of 45,000 psychiatrist and 11000 prescribers. This severely hampers the CMHC's ability to provide services especially in rural and underserved areas. Definition should be: Advanced Practice Psychiatric Nurse Practitioner An individual who specializes in assessing and treating persons having psychiatric disorders; is certified by the American Nurses Credentialing Center as a Psychiatric Clnical Nurse Specialist or Nurse Practitioner and licensed in the state as an advanced practice registered nurse or has documented equivalent education, training or experience, and is fully licensed to practice advanced psychiatric nursing in the State in which he or she practices.