Request for Waiver of the Anesthesia Supervision Requirement to Expire

Seema Verma, MPH
Centers for Medicare & Medicaid Services Department of Health and Human Services
200 Independence Avenue, SW,
Room 445-G Washington, DC 20201

Dear Administrator Verma:

On behalf of our 5 million senior supporters we want to thank you for all the work you are doing regarding the nation’s response to COVID-19.  We are grateful for your leadership and for making the temporary changes to how health care is delivered while we all battle this global pandemic.

We would like to bring to your attention one temporary change regarding Physician Supervision that we hope is just that, temporary.  One of the specific waivers implemented by CMS during this crisis is cutting out essential physician supervision of a nurse anesthetist during the delivery of anesthesia. 

We are sure that you would agree that a nurse practitioner or physician assistant may be able to provide care without physician supervision in certain settings such as home health services and primary care.  However, the surgical setting is a completely different story.  The ability to respond immediately to complications or unexpected changes in the patient’s blood pressure and heart-rate or breathing requires immediate medical attention that only a physician can provide.

We have heard countless stories from seniors on how they have had complications not during surgery but with recovering from the anesthesia and how it was touch and go for them but thanks to fast thinking doctors they survived.  This in no way is intended to be an insult to nurses but to simply point out that nurses and doctors are trained differently and we know if one of our family members or even ourselves were to have complications due to anesthesia we would certainly want an anesthesiologist on the job.

Administrator Verma, on behalf of our constituency, we ask you to allow the waiver of the anesthesia supervision requirement to expire, preserving the team-based model of care in Medicare approved facilities.

Thank you for your consideration and if we can help provide further information please don’t hesitate to contact us.


James L. Martin

Saulius “Saul” Anuzis