I'm no Jet but this is what I posted, tweak away (don't annihilate my writing skills like an oral board
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Hello, this proposed rule change would have considerable negative impact on anesthesia care at the Veterans Administration Hospitals as well as more broadly by impacting the training of future anesthesiologists. First and foremost CRNAs (the anesthesia trained APRNs) have considerably less training than Anesthesiologists (physicians trained in anesthesiology), their schooling is a bachelors of nursing followed by 18 months of clinical training, approximately 1600 hours while a physician anesthesiologist completes a bachelors, a medical doctorate, followed by a minimum of 4 years of specialized anesthesiology residency training, training of which includes 15-16,000 hours of clinical training experience on top of the medical doctorate education. There is quite simply no comparison between the two when it comes medical knowledge or experience. This is particularly important in the acute care surgical arena where potentially life threatening events may occur leaving the anesthesia provider with only seconds to correct. Veterans have been documented in multiple studies to be more chronically and critically ill than the rest of the civilian surgical population, these medical illnesses are not left at the door when a patient enters the operating room for a surgical procedure however "simple or low risk" the actual surgery procedure is viewed as. This is where the expansive medical training of a physician comes into play, anesthesiologists have a background in internal medicine, surgery, and critical care (which is EXACTLY what intraoperative anesthesia is, critical care WHILE undergoing dangerous surgical procedures). This proposed rule change is aimed at filling a void in the primary care of veterans, there has been documented shortages of primary care within the VA, most notably at the Phoenix VA. However, in the VA's own internal assessment of care shortfalls, anesthesiology was not even listed as an at risk area. There simply is no shortage of Anesthesiologist (physician) anesthesia care in the VA system, this IS NOT an access issue. Please understand, that physicians NEED to be involved in the delivery of anesthesia care for our veterans. The inclusion of CRNAs (certified registered nurse anesthetists) in the broadly defined APRN grouping is inappropriate and incongruent with the intent of this legislation. This proposed change would remove the most highly trained and experienced anesthesia provider from the care of veterans, leading to a decrease in the standard of care delivered. Please keep physician anesthesiologists involved, do not support or authorize the categorization of APRNs as fully independent practitioners, our veterans deserve our best.