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Joint Committee on Public Health


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 on bills relative to professional licensure and clinician scope of practice. 

HB1862, SB1278, and SB1350 address issues surrounding the expansion of scope of practice for advanced practice registered nurses (APRNs). MHA supports the expansion of scope of practice for all APRNs, including nurse practitioners, certified registered nurse anesthetists, and psychiatric clinical nurse specialists. We believe that APRNs have the skills and training to be granted pathways to independent practice authority, and recommend that APRN scope expansion should include additional post-graduate training prior to full practice authority or independent practice, including orientation, mentorship, or preceptorship. APRNs should also be granted the ability to supervise the process of their fellow nurses toward independent practice authority. 

In concert with expanded scope, APRNs should be held to the same standards of transparency, accountability, and professional responsibility under which physicians practice. This includes: Ongoing Professional Practice Evaluation (OPPE) and Focused Professional Practice Evaluation (FPPE); public reporting to the Department of Public Health (DPH) or Board of Registration in Nursing; quality reporting tied to the practitioner; public reporting of medical malpractice awards or settlements; mandated medical malpractice liability policy limits; public reporting of any arrangements between practitioner and the pharmaceutical industry; continuing education requirements; and peer review. Like physicians, APRNs must be required to carry professional liability insurance in order to practice. 

APRNs are guided by specialty-related national and local standards of care, their education and training, and specific regulations governing their scope of practice. Consistent with recommendations from The Joint Commission, OPPE is appropriate for all clinicians, including APRNs. There may be gaps in organizational structures supporting OPPE and, where there is appropriate movement towards full practice authority, steps should be taken to ensure that structure and accountability is the same for all licensed independent providers. At the institutional level, APRN scope of practice should be determined by education, training and experience, as it is for physicians. It should be expected and verified that an individual’s practice is within their education, training, and experience, and that they function within professional boundaries with ongoing professional evaluations. 

Evolving models of team-based care delivery are currently practiced by healthcare organizations and should be led by the licensed, independent health care professional best suited to guide other members of the team given the setting of care. APRNs play a critical role in these collaborative models and MHA believes that they should have the ability to practice at the top of their license. 

While MHA supports the intent of HB1888/SB1340, we urge the committee to consider the addition of further protections to this proposal. HB1888/SB1340 provides important liability protections to registered nurses who volunteer services in a disaster or emergency without compensation or expectation of payment. It provides a means of financial coverage to a volunteer in cases of injuries, disabilities, or death. While this is a very important coverage item, it should also include protections for all members of the healthcare team that provide these services to patients. We strongly encourage the committee to expand the bill to specifically apply to a “healthcare provider” – a term defined in Section 1 of Chapter 111 of the General Laws. All healthcare providers should be afforded these protections when volunteering services during public health emergencies. 

Additionally, MHA supports HB1849/SB1297 that would recognize in Massachusetts statute the role of pharmacists as healthcare providers. Hospitals currently use pharmacists at the top of their license alongside a multidisciplinary team of healthcare providers to achieve healthy outcomes for patients. For those with complex medical conditions taking multiple medications, a pharmacist’s clinical services are invaluable to optimize therapeutic outcomes. Currently under collaborative care agreements with supervising physicians, pharmacists can: perform patient assessment, including a physical assessment; prescribe appropriate medications and deliver evidence-based collaborative drug therapy/medication therapy management within the scope of the supervising physician; order, interpret, and monitor laboratory tests; formulate clinical assessments and develop therapeutic plans based upon the patient’s response to treatment; and perhaps most importantly, provide care coordination, patient education, and other health services for wellness and prevention of disease to partner with patients for ongoing care and education leading to improved outcomes. The positive, cost saving results of pharmacist involvement with the medication therapy of chronic disease patients are well described in peer reviewed literature. Recognition of pharmacists as healthcare providers as proposed in HB1849/SB1297 would clear obstacles to expand the number of pharmacists who are providing direct patient care in collaboration with physicians. 

MHA also supports HB2000. This legislation would require the Board of Registration in Medicine to submit to the DPH commissioner for approval of any rule or regulation that the board is considering adopting, amending, or repealing. Such additional oversight from the commissioner would ensure consistency in state public health regulations and appropriate oversight for the welfare of the patients of the commonwealth.