In these two letters to the Board of Registration in Medicine (BORIM), MHA expressed concerns shared by a wide segment of the provider community that BORIM’s proposed substantial changes to its regulations would increase healthcare costs and administrative burdens while decreasing the time providers can spend on patient care.
As an example, the proposed recent changes to BORIM’s “Licensing and Practice of Medicine” requirements impose several new informed consent and patient notification requirements that MHA said in its letter will delay patient care and appear to be in direct conflict with the governor’s 2015 Executive Order seeking to reduce inconsistent and redundant requirements. In addition, much of the reporting BORIM included in its proposed regulation is already covered by existing reports to BORIM, DPH, and other state and federal agencies.
MHA said in its letter that the proposed changes to the regulations will also increase credentialing and licensure criteria that will delay the processing of licensure applications. Physicians currently wait several months for their licensure application to be approved in order to provide services in the commonwealth; BORIM’s proposed regulations would add further delays, MHA said.
In its letter, MHA indicated that providers are concerned that BORIM did not seek to expand use of innovative technology, such as telemedicine, that many regulators, providers, and advocates agree would enhance access to critical services, such as those relating to behavioral health and substance use disorders. As drafted, the regulations indicate the use of telemedicine would only be allowed within a hospital or nursing home, in limited circumstances. Anuj Goel, MHA’s VP of Legal and Regulatory Affairs, who drafted MHA’s letter, said BORIM missed an opportunity to work with the provider community to improve services and facilities in a manner consistent with state and federal healthcare reform and system innovation goals.