Joint Committee on Consumer Protection & Professional Licensure
The Massachusetts Health & Hospital Association (MHA), on behalf of its member hospitals, health systems, physician organizations and allied healthcare providers, appreciates this opportunity to offer comments in opposition to HB1974/HB1981, “An Act Establishing a Board of Registration of Phlebotomists
HB1974/HB1981 would create a significant burden and increased costs on both phlebotomists and hospitals that rely upon phlebotomist services. Phlebotomy, also known as venipuncture, requires technical skills, adherence to aseptic techniques, and training in blood borne pathogens. Most phlebotomists are trained by healthcare facilities to provide a core technical function as part of the overall care that is provided to patients. They are not specialized workers who go through intensive training and education similar to a physician or nurse. Phlebotomists do not require the level of oversight that a specific board of registration would provide to a group that is effectively managed by healthcare facilities as a part of a patient care team.
Additionally, other clinical positions such as licensed practical nurses, registered nurses, emergency medical technicians and paramedics perform phlebotomy. The creation of a specific board of registration will create ambiguity and complexity as to whether these other clinical positions will need additional licensure or registration. At the very least, the committee should consider expanding the list of exempt professionals to be more inclusive than scientists, physicians, and certain technicians. The time, effort, and increased costs to apply for and exempt all healthcare professionals that provide this service to patients will only increase the costs to the entire healthcare system.
It is also important to note that there are different procedures involved in the drawing of blood. For example, HB1974/HB1981 defines “Phlebotomy” as the incision into a vein or artery for the purpose of drawing blood. However, this definition also encompasses other clinical procedures including arterial blood drawing, which is much a more risky procedure and is currently performed by a limited number of professionals, such as physicians, registered nurses, and registered respiratory technologists with specific skills and competencies. MHA believes that it is not appropriate to create such definitions or licensure criteria for phlebotomists that do not fully recognize the work performed by other licensed hospital staff, which may lead to significant confusion as to the determination of scope of practice allowances for these healthcare providers. For these reasons we urge the committee to oppose HB1974/HB1981.
Thank you for the opportunity to offer testimony on this matter. If you have any questions regarding this testimony, or require further information, please contact Michael Sroczynski, MHA’s Vice President of Government Advocacy, at (781) 262-6055 or msroczynski@mhalink.org.