Joint Committee on Health Care Financing
The Massachusetts
Health & Hospital Association (MHA), on behalf of our member hospitals,
health systems, physician organizations and allied health care providers,
appreciates the opportunity to submit comments in opposition to HB621, “An Act Relative to Accessible
Medical Equipment”, as drafted.
While MHA supports
the principles addressed by in HB621, we oppose the bill as drafted.
This legislation requires the Department of Public Health (DPH) to put forward
regulations on minimum technical criteria for medical diagnostic equipment.
This would create a duplicative regulatory structure that is already in place
for hospitals and would add unnecessary costs to the state and the provider
community.
As part of the
provider tax that was levied on hospitals to fund the MassHealth
Delivery System Reform Trust Fund in the FY17 budget, every acute care hospital
is now required to provide detailed reporting to the Medicaid program on the
types and number of accessible equipment for persons with disabilities. The reporting that was developed by the state
specifically takes into account the federal standards that all
healthcare providers are required to follow including: (1) the United States Access
Board’s “Standards for Medical
Diagnostic Equipment” that provides design criteria
and technical requirements for accessing medical diagnostic equipment; (2) the
U.S. Department of Justice’s (which enforces the Americans with Disabilities
Act (ADA)) technical assistance guide that outlines how providers should
provide access to medical care for individuals with mobility disabilities; and
(3) the Occupational Safety and Health Administration (OSHA) ergonomics standards, that outlines
recommendations for staff to work with patients to minimize workplace injuries.
While every hospital
constantly evaluates its buildings and equipment to ensure there is appropriate
access for patients with disabilities following the federal standards above, it
is clear that the goals and principles of HB621
are already being implemented in the state through the reporting
requirements of MassHealth. Therefore, HB621 would be duplicative and
potentially could lead to conflicting standards for hospitals. For these reasons we urge the committee to
take no action on HB621.
Thank you for the opportunity to offer comments on this important matter. If you have any questions or require further information, please contact MHA's Vice President of Government Advocacy, Michael Sroczynski, at (781) 262-6055 or
msroczynski@mhalink.org.