Joint Committee on Mental Health Substance Use & Recovery
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 legislation related to professional licensure, scope of practice and other workforce issues related to behavioral health providers.
MHA supports HB1704, which would create a behavioral health workforce development trust fund to support the training and employment of licensed mental health clinicians, social workers, and other masters level behavioral health providers. Increasing the number of licensed mental health clinicians and social workers in both institutional and community-based settings would provide necessary support to patients in the community and through acute inpatient placements. The current shortage of behavioral health providers can be attributed to a variety of factors, including the lack of appropriate payments and high educational costs. MHA recently partnered with other stakeholders in the Behavioral Health Unfinished Agenda of Reform (BHUAR) initiative which brought together providers, payers, government, and community-based agencies to look at solutions to improving access to behavioral health services. One of the key areas prioritized is the effort to enhance the insufficient supply of qualified behavioral health professionals. The current shortage contributes to extended wait times for patients and delayed access to care. Proposals such as HB1704 will provide additional financial support for professional development in the behavioral health field and will increase the number of providers available to support the care and treatment of those with substance use and mental health diagnoses. MHA would ask the committee to consider including MHA as a standing member of the Massachusetts Behavioral Health Workforce Development Trust Fund, given our ongoing work in this area.
MHA supports HB1730/ SB1157, which would expand the authority of a psychiatric clinical nurse specialist to have full ability to prescribe medications as well as order and interpret tests without physician oversight. In addition, it would streamline regulatory oversight so that these nurses would be overseen through the Board of Registration in Nursing (BORN) only, instead of having to meet oversight by both the BORN as well as the Board of Registration in Medicine. MHA believes that this bill addresses the ongoing problems in accessing medically necessary behavioral health services in the Commonwealth.
MHA supports the expansion of scope of practice for psychiatric clinical nurse specialists and of pathways to independent practice authority. Consistent with the recommendations of the MHA APRN (Advanced Practice Registered Nurse) Task Force, MHA is supportive of: 1) proposals to require additional post-graduate training prior to full practice authority or independent practice, including orientation, mentorship, preceptorship or support; 2) the recommendation that the BORN should solely promulgate APRN regulations and scope of practice in Massachusetts; 3) the recommendation that APRNs should be held to the same standards of transparency, accountability, and professional responsibility under which physicians practice; and 4) comparable to physicians, APRNs must carry professional liability insurance in order to practice.
MHA also supports HB1731, which seeks to expand the ability for psychiatric clinical nurse specialists to provide the same level of services as a physician. Currently, a Nurse Practitioner has the full authority to sign and verify the physical and mental health treatment for a patient similar to a physician. HB1731 would expand this authority to include psychiatric clinical nurse specialists. At a time when there is a serious shortage of psychiatrists in the Commonwealth who are able to evaluate, approve and provide services, expanding the authority for psychiatric clinical nurse specialists through HB1730 / SB1157 and HB1731 will ensure greater access and care services for behavioral health patients, and reduce overall emergency department boarding statewide.
MHA also supports HB3722, which allows qualified nurse practitioners to admit patients to inpatient psychiatric facilities and to authorize use of restraints. Along with other behavioral health care settings, inpatient psychiatric facilities face a shortage of psychiatrists and this legislation would help facilities address these workforce shortages by allowing qualified nurse practitioners to practice at the top of their license. MHA suggests amending this legislation to allow psychiatric clinical nurse specialists similar authority.
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 Senior Vice President of Government Advocacy at (781) 262-6055 or msroczynski@mhalink.org