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The filing evaluates nursing regulation through a competition lens, arguing that unnecessary or overly broad supervision requirements can raise costs, impede access, and hinder innovative team-based care, with added risks in rural and medically underserved areas. It also cautions against adopting an amendment that shifts regulatory control away from the Kansas Board of Nursing.",{"@graph":69,"@context":114},[70,84,105],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":40,"@type":76,"position":81},"https://docshare.wps.com/document/research-report/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/federal-trade-commission-comments-on-2019-house-bill-2412-advanced-practice-registered-nurses-in-kansas/328260/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/federal-trade-commission-comments-on-2019-house-bill-2412-advanced-practice-registered-nurses-in-kansas/328260.png","ImageObject",300,407,{"name":92,"@type":93},"Margaret","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-10-30","2026-09-21",true,{"@type":102,"interactionType":103,"userInteractionCount":29},"InteractionCounter",{"@type":104},"ViewAction",{"@type":106,"mainEntity":107},"FAQPage",[108],{"name":109,"@type":110,"acceptedAnswer":111},"What concerns does the FTC raise about mandatory physician supervision or collaborative practice agreements?","Question",{"text":112,"@type":113},"The FTC argues such restrictions may be unnecessary or overly broad, potentially raising the cost of care, limiting access, and frustrating development of effective team-based care models.","Answer","https://schema.org",{"og:url":83,"og:type":116,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":118,"canonical":83},"index,follow",{"doc_id":120,"site_id":62},328260,1791506333,{"code":4,"msg":5,"data":123},{"doc_id":120,"user_id":124,"nickname":92,"user_avatar":125,"doc_module":4,"category_id":39,"category_name":40,"doc_title":65,"doc_description":67,"doc_content":126,"file_id":127,"file_url":128,"file_type":129,"file_size":130,"view_count":29,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":131,"language":132,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":133,"faqs":134,"seo_title":135,"seo_description":67,"update_tm":136,"read_time":137,"preview_page_count":4},137451207643,"https://ap-avatar.wpscdn.com/davatar_3d24733baf745e90a7e4bdd5f77d97b2","January 09,2020  \nThe Honorable Daniel R.HawkinsKansas House of RepresentativesState CapitolTopeka,KS 66612  \nDear Representative Hawkins:  \nThe Federal Trade Commission(\"FTC\"or“Commission”)Office of Policy Planningappreciates the opportunity to respond to your request for comments on 2019 House Bill 2412(\"H.B.2412”or “the Bill\"),a proposal to expand the scope of practice of Advanced PracticeRegistered Nurses(“APRNs”)in Kansas.'In particular,you asked for our input on the Bill'sproposal to \"permit APRNs full practice authority by eliminating a requirement that APRNsmust have a collaborative practice agreement executed with a physician in order to prescribemedications.”2 You have also asked for our comment on a proposed amendment “to require allAPRNs to be under the regulatory control of the physician-controlled Kansas Board of HealingArts rather than the Kansas Board of Nursing where they are currently regulated.\"³For reasonsexplained below,we urge the Kansas legislature to enact H.B.2412 and rescind the collaborativeagreement requirement;in doing so,we urge you not to adopt the proposed amendmentregarding regulation by the Board of Healing Arts.  \nFTC staff's interest in nursing regulation derives from our expertise in health carecompetition issues.The enclosed 2014 FTC staff policy paper,Policy Perspectives:Competitionand the Regulation of Advanced Practice Registered Nurses(“Policy Paper”),analyzes thecompetitive implications of various Advanced Practice Registered Nurse(“APRN”)regulations,including mandatory physician-supervision or“collaborative practice”agreements.⁴As  \n³Id.  \nexplained in the Policy Paper,FTC staff recognize the critical importance of patient health andsafety,and we defer to federal and state legislators to determine the best balance of policypriorities and to define the appropriate scope of practice for APRNs and other health careprofessionals.But even well-intentioned laws and regulations may include unnecessary oroverbroad restrictions that limit competition.Undue regulatory restrictions on APRN practicecan harm patients,institutional health care providers,and both public and private third-partypayors.The Policy Paper observes that state-mandated supervision of APRN practice raisescompetitive concerns and may,in particular,raise the cost of care,impede access to care,andfrustrate the development ofinnovative and effective models of team-based health care.⁵  \nAs noted in the Policy Paper,the competitive risks associated with undue APRNrestrictions may be heightened in rural and other medically underserved areas.⁶For that reason,the legislature may wish to focus not just on average or aggregate benefits that the Bill maypromote for Kansas as a whole,but on health care cost and access problems facing,for example,the 66 Kansas counties that are Governor-Designated Medically Underserved Areas,⁷based onassessed shortages of primary care physicians.8  \nExpert bodies,including the Institute of Medicine(\"IOM\"),9 have determined thatAPRNs are \"safe and effective as independent providers of many health care services within thescope of their training,licensure,certification and current practice.”10FTC staff have  \nrecommended,therefore,that policy makers carefully examine purported safety justifications forrestrictions on APRN practice in light of the pertinent evidence,evaluate whether suchjustifications are well founded,and consider whether less restrictive alternatives would protectpatients without imposing undue burdens on competition and undue limits on patients'access tobasic health care services.  \nFTC staff urge the Kansas legislature to apply a similar analytical framework.Grantingprescribing authority to Kansas APRNs would benefit Kansas health care consumers-patients,first and foremost,and both public and private third-party payors.APRNs should be able toevaluate patients and prescribe medications as needed,as long as they do so within the limits of  \nsecuring the approval of an individual physician,w","cbCaiqO6ydXLGko0","https://ap.wps.com/l/cbCaiqO6ydXLGko0","pdf",1359990,11,"English","# I. Interest and Experience of the FTC\n## Competition, consumer welfare, and health care enforcement focus","[{\"question\":\"What concerns does the FTC raise about mandatory physician supervision or collaborative practice agreements?\",\"answer\":\"The FTC argues such restrictions may be unnecessary or overly broad, potentially raising the cost of care, limiting access, and frustrating development of effective team-based care models.\"}]","Federal Trade Commission Comments on 2019 House Bill 2412 - Advanced Practice Registered Nurses in Kansas | PDF",1789979095,28]