Joint Committee on Public Health
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 on the following bills regarding organ procurement organizations and consumer protection rights for patients.
MHA supports HB2467. This bill extends the consumer protection rights under the Office of Patient Protection at the Health Policy Commission (HPC) to all residents of the Commonwealth. The right to a timely internal appeal process with an insurer as well as the right to file an independent external review following an adverse determination by an insurer should be extended to all patients in the Commonwealth. The current protections only apply to payers in commercial health insurance plans.
MHA is strongly opposed to HB2466, which would implement a state based registration, oversight, donor registration, and data reporting requirement on an organ procurement organization (OPO) that is different from - but not as rigorous as - federal regulatory requirements. Every OPO in the country must follow strict federal rules and policies for how organs and tissue are donated and shared within the state and across the country. In particular, every OPO is regulated by multiple federal government agencies and must adhere to the highest medical and ethical standards. OPOs also utilize the newest scientific technology to facilitate medical advancements that ensure critically ill patients are able to receive safe tissues/organs for life saving transplant services. For these reasons we are strongly opposed to imposing a duplicative state-based registration process as envisioned in HB2466 on organizations and donors that would only serve to reduce the interest of potential donors in our state. At a time when there are a number of patients on organ wait lists that need lifesaving transplant services, it is against the public interest to unnecessarily increase administrative requirements and therefore delay access to organs for critical patients who have time sensitive medical needs.
Thank you for the opportunity to offer comments on these important matters. If you have any questions or concerns or require further information, please contact Michael Sroczynski, MHA’s Vice President of Government Advocacy, at (781) 262-6055 or firstname.lastname@example.org.