11 September 2023

Department of Health
Board of Medicine
c/o Members of the Florida Board of Medicine
RE: PR🌙 SOMNIA Sleep ® Petition for
Declaratory Statement Before the Florida Board of Medicine
4052 Bald Cypress Way Bin C-03
Tallahassee, FL 32399-3253

Esteemed Members of the Medical Board of Florida,

I hope this message finds you well rested. My name is Nyree Penn, CAA #264, and I am honored
to represent PROSOMNIA Sleep ®; an organization dedicated to pioneering advancements in
clinical sleep therapy. I am writing to formally present our petition for a Declaratory Statement,
one that carries the promise of elevating sleep health across Florida and extending its impact
globally. At the same time, this petition seeks to bring parity to the professional landscape,
ensuring that Certified Anesthesiologist Assistants (CAAs) enjoy indirect supervision and
prescriptive rights comparable to those of our professional midlevel, counter-parts, Advanced
Registered Nurse Practitioners (ARNPs) and Physician Assistants (PAs).

As conscientious stewards of healthcare, you are undoubtedly aware of the importance of a

Declaratory Statement. It allows individuals, like us, who are substantially affected by healthcare
regulations, to seek clarity and fairness in the application of statutes, rules, or orders. This
provision embodies the spirit of fairness and innovation that is essential for a healthcare system
to thrive.

PR🌙 SOMNIA Sleep’s ® Petition is motivated by four vital considerations:

🌙 Expanded Practice Privileges for CAA's:

PROSOMNIA Sleep stands at the forefront of global sleep health and wellness. We employ an
innovative blend of clinical expertise, innovation, and a multidisciplinary team of healthcare
experts, including Board-Certified Anesthesiologists and CAAs. Our mission is clear: to
diagnose and treat sleep disorders, such as sleep deprivation, insomnia, and REM sleep
disorders, with a level of excellence and safety that is unparalleled.

To fully achieve this mission, we request the opportunity to operate in the full scope of practice
under the indirect supervision of a Board-Certified Anesthesiologist. This expansion in practice
privileges will not only revolutionize sleep health in Florida but will also serve as a model for the
world. Our contemporary practices will enhance patient outcomes, reduce healthcare costs, and
provide much-needed access to high-quality sleep care.
🌙 Prescriptive Rights for CAAs:

CAAs, ARNPs, and PAs share a common thread of excellence in healthcare. Yet, there exists a
discrepancy in prescriptive rights that cannot be overlooked. CAAs, with their academically
identical, extensive anesthesia education, superior training and clinical expertise, deserve the
same prescriptive rights enjoyed by ARNPs and PAs. This equal footing in prescriptive authority
will not only uphold the tenets of fairness but will also enhance patient care and streamline
healthcare delivery.

🌙 The Broader Impact:

Our petition transcends the boundaries of PR🌙 SOMNIA Sleep ® and CAAs. It advocates for
innovation, equity, and excellence in healthcare. By recognizing PROSOMNIA Sleep's unique
contributions and granting us expanded practice privileges and CAAs equal prescriptive rights,
Florida has the opportunity to lead the world in sleep health transformation and in promoting
fairness in healthcare.

🌙 Seeking Your Support:

We kindly request your invaluable support in granting this Declaratory Statement. Our vision
aligns seamlessly with the goals of improving patient care, rectifying professional imbalances,
and upholding the principles of fairness within our healthcare system. The potential positive
impact of your decision is not just exciting; it's monumental.

Thank you for dedicating your time and consideration to this pivotal matter. Your commitment to
excellence and fairness in healthcare is truly appreciated.

#GetPROSOMNIAsleep,

Nyree Penn, MHSc., CAA

Founder & CEO
PR🌙 SOMNIA Sleep ® LLc
2820 NE 214th Street
Suite #817
Aventura, FL 33180
954.283.0044
info@prosomniasleep.com
www.prosomniasleep.com