In response to a 2015 Supreme Court anti-trust ruling in North Carolina State Board of Dental Examiners vs. Federal Trade Commission, there has been a recent trend of states seeking to consolidate medical licensing boards in order to facilitate increased state oversight of board antitrust actions. Proponents of these bills, including state lawmakers and some physicians groups, say they provide increased accountability in the licensing process, opportunity and competitiveness for those operating in a specific field, and the ability to implement cost-saving measures.

These efforts have been met with opposition by a number of medical professional associations, including many of the health care provider groups affected by the bills, who believe consolidated boards would be detrimental to public protection because each profession licensed by a regulatory board is unique in training and scope of practice. As examples, these associations argue that a social worker would not have the knowledge to judge the credentials, ethics and work of a psychologist; and a marriage and family therapist would not have the information needed to recommend disciplinary action for a licensed professional counselor. 

The debate over the pros and cons of consolidated professional boards continues in several states including the following:

OH: Failed 2016 bill would have reduced the number of medical-licensure boards from 16 to eight — and cut the number of board members by 88.

AZ: Failed 2016 bill proposed to consolidate 18 health and medical regulatory boards under the umbrella of a single state agency, the Arizona Department of Health Services.

NC: In 2016, a state legislative subcommittee approved draft legislation that would dissolve 15 occupational licensing boards in the state. The draft legislation never made it out of the Joint Legislative Administrative Procedure Oversight Committee after members in the professions whose boards faced reform came out in force against the legislation.

TX: Sunset Advisory Commission issued a report in November 2016, and found that the independent structure of the State’s health licensing agencies was antiquated and inefficient. The report recommends that the state transfer 10 health occupational licensing programs to the Health Professions division at Texas Department of Licensing and Regulation and reconstitute the associated regulatory boards as advisory boards.

Centers for Medicare & Medicaid Services (CMS)

CPR responded to a CMS Request For Information regarding the Patient Protection and Affordable Care Act: Reducing Regulatory Burden and Increasing Healthcare Choices to Empower Patients.

Read the full letter

Department of Veterans Affairs

CPR wrote a comment letter regarding the Department of Veterans Affairs’ proposed regulation on Advanced Practice Registered Nurses (APRNs). The regulation was finalized in December 2016. Read the full letter.

American College of Cardiology

CPR responded to the American College of Cardiology's 2015 ACC Health Policy Statement on Cardiovascular Team-Based Care and the Role of Advanced Practice Providers. Read the full letter.

Federal Trade Commission (FTC)

CPR submitted an official comment letter to the Federal Trade Commission in response to their public workshop "Examining Health Care Competition. Project No. P131207." The letter emphasized CPR’s support for the FTC’s efforts to address health care monopolies and reaffirms CPR’s commitment to ensuring patients everywhere have access to the quality health care providers of their choice. Read the full letter.

FTC submitted a letter to CPR offering support of protecting health care competition and provider access for consumers. Read the full letter.

U.S. Department of Health and Human Services

CPR responded to a HHS RFI seeking information about promoting health care choice and competition across the United States. 

Read the full letter.

CPR condemned flawed guidance on provider non-discrimination law. Read the full document.

U.S. Congress

CPR urged Congress to protect access to health care providers by rejecting a bill that would repeal the “non-discrimination” clause in the Affordable Care Act, which ensures services provided by a full range of health care professionals are covered by insurance plans. Read the full letter.

CPR monitors regulatory and legislative issues at the state and national levels that promote scope of practice restrictions, as well as the American Medical Association’s Scope of Practice Partnership initiative that seeks to do the same. We actively advocate for patient access to health services and patient choice of health care providers without undue restrictions.

State Initiatives

CPR Responses to the AMA 

The American Medical Association's (AMA) Scope of Practice Partnership (SOPP) is an effort to restrict the practice of health care professionals who are not doctors of medicine (M.D.s) or osteopathy (D.O.s). This effort would limit patients' abilities to choose their health care providers and restrict access to safe, high-quality and cost-effective health care.

Click here for CPR's response to the AMA Resolution 214

Click here for CPR's statement regarding the AMA's Scope of Practice Modules.

Click here for CPR's letter to the AMA regarding regarding the Scope of Practice Modules

Advocacy and Legislation

Federal Initiatives