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It describes nurse practitioners’ scope of practice, prescriptive authority across all states and DC, and the scale of their patient visits, emphasizing the need for inclusive rulemaking involving patients and providers.",{"@graph":14,"@context":73},[15,34,56],{"@type":16,"itemListElement":17},"BreadcrumbList",[18,23,27,31],{"item":19,"name":20,"@type":21,"position":22},"https://docshare.wps.com","Home","ListItem",1,{"item":24,"name":25,"@type":21,"position":26},"https://docshare.wps.com/document/","Document",2,{"item":28,"name":29,"@type":21,"position":30},"https://docshare.wps.com/document/healthcare/","Healthcare",3,{"item":32,"name":10,"@type":21,"position":33},"https://docshare.wps.com/document/special-registrations-for-telemedicine-and-limited-state-telemedicine-registrations-comment-letter/328233/",4,{"url":32,"name":10,"@type":35,"image":36,"author":41,"headline":10,"publisher":44,"fileFormat":47,"inLanguage":8,"description":12,"dateModified":48,"datePublished":49,"encodingFormat":47,"isAccessibleForFree":50,"interactionStatistic":51},"DigitalDocument",{"url":37,"@type":38,"width":39,"height":40},"https://docshare.wps.com/thumbnails/special-registrations-for-telemedicine-and-limited-state-telemedicine-registrations-comment-letter/328233.png","ImageObject",300,407,{"name":42,"@type":43},"Lucas Vance","Person",{"url":19,"name":45,"@type":46},"DocShare","Organization","application/pdf","2026-10-26","2026-09-21",true,{"@type":52,"interactionType":53,"userInteractionCount":55},"InteractionCounter",{"@type":54},"ViewAction",14,{"@type":57,"mainEntity":58},"FAQPage",[59,65,69],{"name":60,"@type":61,"acceptedAnswer":62},"What is the AANP’s position on the proposed DEA telemedicine registration rule?","Question",{"text":63,"@type":64},"AANP requests that the rule be withdrawn, stating it does not adhere to access and patient choice principles.","Answer",{"name":66,"@type":61,"acceptedAnswer":67},"What changes does AANP ask DEA and HHS to make regarding telemedicine flexibilities?",{"text":68,"@type":64},"AANP asks DEA and HHS to extend the existing telemedicine flexibilities through 2026 and to conduct inclusive rulemaking.",{"name":70,"@type":61,"acceptedAnswer":71},"Why does the letter emphasize nurse practitioners’ role in telehealth and patient access?",{"text":72,"@type":64},"The letter explains that NPs provide primary and specialty care, hold prescriptive authority across all states and DC, and deliver large volumes of patient visits, making access restrictions particularly impactful.","https://schema.org",{"og:url":32,"og:type":75,"og:title":10,"og:site_name":45,"og:description":12},"article",{"robots":77,"canonical":32},"index,follow",{"doc_id":79,"site_id":7},328233,1790469369,{"code":4,"msg":82,"data":83},"success",[84,88,92,96,101,106,110,115,120,123,127],{"id":22,"doc_module":4,"doc_module_name":25,"category_name":85,"show_sort_weight":86,"slug":87},"Story & Novel",90,"story-novel",{"id":26,"doc_module":4,"doc_module_name":25,"category_name":89,"show_sort_weight":90,"slug":91},"Literature",80,"literature",{"id":33,"doc_module":4,"doc_module_name":25,"category_name":93,"show_sort_weight":94,"slug":95},"Exam",70,"exam",{"id":97,"doc_module":4,"doc_module_name":25,"category_name":98,"show_sort_weight":99,"slug":100},5,"Comic",60,"comic",{"id":102,"doc_module":4,"doc_module_name":25,"category_name":103,"show_sort_weight":104,"slug":105},6,"Technology",50,"technology",{"id":107,"doc_module":4,"doc_module_name":25,"category_name":29,"show_sort_weight":108,"slug":109},7,40,"healthcare",{"id":111,"doc_module":4,"doc_module_name":25,"category_name":112,"show_sort_weight":113,"slug":114},8,"Research & Report",30,"research-report",{"id":116,"doc_module":4,"doc_module_name":25,"category_name":117,"show_sort_weight":118,"slug":119},9,"Religion & Spirituality",20,"religion-spirituality",{"id":118,"doc_module":4,"doc_module_name":25,"category_name":121,"show_sort_weight":118,"slug":122},"World Cup","world-cup",{"id":124,"doc_module":4,"doc_module_name":25,"category_name":125,"show_sort_weight":124,"slug":126},10,"Lifestyle","lifestyle",{"id":128,"doc_module":4,"doc_module_name":25,"category_name":129,"show_sort_weight":97,"slug":130},19,"General","general",{"code":4,"msg":82,"data":132},{"doc_id":79,"user_id":133,"nickname":42,"user_avatar":134,"doc_module":4,"category_id":107,"category_name":29,"doc_title":10,"doc_description":12,"doc_content":135,"file_id":136,"file_url":137,"file_type":138,"file_size":139,"view_count":55,"is_deleted":4,"is_public":22,"is_downloadable":22,"audit_status":22,"page_count":111,"language":140,"language_code":8,"site_id":7,"html_lang":8,"table_of_contents":141,"faqs":142,"seo_title":143,"seo_description":12,"update_tm":144,"read_time":118},549768064622,"https://ap-avatar.wpscdn.com/davatar_6f874abed73319feea01a86fa6f0fab8","March 17, 2025  \nHeather E. Achbach  \nRegulatory Drafting and Policy Support Section  \nDiversion Control Division, Drug Enforcement Administration (DEA)  \nDepartment of Justice 8701 Morrissette Drive Springfield, VA 22152  \nRE: Special Registrations for Telemedicine and Limited State Telemedicine Registrations  \nDear Ms. Achbach,  \nThe American Association of Nurse Practitioners (AANP), representing more than 431,000 nurse practitioners (NPs) in the United States, appreciates the opportunity to comment on this proposed rule, Special Registrations for Telemedicine and Limited State Telemedicine Registrations. We appreciate actions taken by the first Trump Administration to implement the Comprehensive Addiction and Recoveries Act (CARA) and the Support for Patients and Communities Act, both of which recognized the importance of ensuring access to necessary care. The first Trump administration was also the first to utilize the waiver authority under the Ryan Haight Online Pharmacy Consumer Protection Act of 2008 (the “Ryan Haight Act”) pursuant to the COVID-19 Public Health Emergency (PHE) . However, we are deeply concerned that this rule as proposed under the previous administration does not adhere to the principles of access and patient choice. Therefore, we respectfully request that this rule be withdrawn, and DEA and HHS extend these flexibilities through 2026 while undertaking a proposed rulemaking process which is inclusive of patients and providers. Should this proposed rule be the basis for a continued rulemaking process, we request that it be substantially altered to meet the intent of the Ryan Haight Act. As proposed, this rule would establish burdensome and impractical restrictions on providers and patients who utilize telehealth as their modality of care. We look forward to working with the agency on a rule which recognizes the importance of patient access to care.  \nAs you know, NPs are advanced practice registered nurses (APRNs) who are prepared at the masters or doctoral level to provide primary, acute, chronic and specialty care to patients of all ages and backgrounds. Daily practice includes assessment; ordering, performing, supervising and interpreting diagnostic and laboratory tests; making diagnoses; initiating and managing treatment including prescribing medication and non-pharmacologic treatments; coordinating care; counseling; and educating patients and their families and communities. NPs hold prescriptive authority in all 50 states and the District of Columbia (D.C.) and perform nearly one billion patient visits annually. Currently, twentyseven states, the District of Columbia and two U.S. territories have adopted full practice authority (FPA), granting patients full and direct access to nurse practitioners.  \nNPs practice in nearly every geographic region and health care setting including hospitals, clinics, Veterans Health Administration and Indian Health Services facilities, emergency rooms, urgent care sites, private physician or NP practices (both managed and owned by NPs), skilled nursing facilities (SNFs) and nursing facilities (NFs), schools, colleges and universities, retail clinics, public health departments, nurse managed clinics, homeless clinics, and provide the most home-based care to Medicare beneficiaries.  \nNurse practitioners provide a substantial portion of the high-quality1, cost-effective2 care that our  \ncommunities require. As of 2021, there were over 193,000 NPs billing for Medicare services, making NPs  \n1 [https://www.aanp.org/images/documents/publications/qualityofpractice.pd](https://www.aanp.org/images/documents/publications/qualityofpractice.pdf)[f](https://www.aanp.org/images/documents/publications/qualityofpractice.pdf).  \n2 [https://www.aanp.org/images/documents/publications/costeffectiveness.pdf](https://www.aanp.org/images/documents/publications/costeffectiveness.pdf).  \nthe largest and fastest growing Medicare designated provider specialty.3 Approximately 40% of Medicare","cbCaif9p4ZZRfSJC","https://ap.wps.com/l/cbCaif9p4ZZRfSJC","pdf",328073,"English","# Special Registrations for Telemedicine and Limited State Telemedicine Registrations\n## Request to withdraw and extend telemedicine flexibilities through 2026\n## Role and impact of nurse practitioners in patient access","[{\"question\":\"What is the AANP’s position on the proposed DEA telemedicine registration rule?\",\"answer\":\"AANP requests that the rule be withdrawn, stating it does not adhere to access and patient choice principles.\"},{\"question\":\"What changes does AANP ask DEA and HHS to make regarding telemedicine flexibilities?\",\"answer\":\"AANP asks DEA and HHS to extend the existing telemedicine flexibilities through 2026 and to conduct inclusive rulemaking.\"},{\"question\":\"Why does the letter emphasize nurse practitioners’ role in telehealth and patient access?\",\"answer\":\"The letter explains that NPs provide primary and specialty care, hold prescriptive authority across all states and DC, and deliver large volumes of patient visits, making access restrictions particularly impactful.\"}]","Special Registrations for Telemedicine and Limited State Telemedicine Registrations - Comment Letter | PDF",1789979009]