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COMMENTS OF THE PENNSYLVANIA STATE NURSES ASSOCIATION
TO THE PROPOSED RULEMAKING OF THE STATE BOARD OF MEDICINE CONCERNING THE DELEGATION OF MEDICAL SERVICES
Regulation 16A-4912

Submitted October 9, 2001

The Pennsylvania State Nurses Association submits the following comments to the Proposed Rulemaking of the State Board of Medicine concerning the Physician Delegation of Medical Services. This proposed regulation was published in the Pennsylvania Bulletin on September 8, 2001, requesting comments in thirty days, October 9, 2001.

As presently drafted the proposed regulation has the potential to inappropriately expand the scope of practice of unlicensed personnel that may be working for a medical doctor in an office or other setting, has the potential to create inconsistencies with statutes and regulations governing the practices of other health care practitioners, and has the potential to establish yet another difference between the practices of medical doctors and osteopathic physicians. All of these potential outcomes of the regulation can pose significant risks to the public. For these reasons the Pennsylvania State Nurses Association must oppose these regulations as currently drafted....

"Since there is no definition of health care practitioner or technician and no standards for the medical doctor to determine education, training or competency, the proposed regulation appears to allow unlicensed personnel that may be working for a medical doctor in an office or other setting to provide services that are licensed activities. ".......

Full reply @ http://www.psna.org/HotIssues/delegation.htm