Testimony in Opposition to H.1067 and S.1109 before the Joint Committee on Mental Health, Substance Use and Recovery

The Massachusetts Medical Society wishes to be recorded in opposition to H.1067/S.1109. These identical bills would remove the existing statutory framework underlying the relationship between physicians and psychiatric nurse practitioners and would allow psychiatric nurse mental health clinical specialists to issue written prescriptions and order and interpret tests. 

This legislation provides no public protections or standards to replace the legal basis for the functioning team approach to collaborative and supervisory relationships among psychiatric nurses and physicians which has served the Commonwealth so well over the years.

The Massachusetts Medical Society urges the legislature not to expose the public, particularly our most vulnerable patients, to the independent practice of individuals with minimal training and no oversight whatsoever. A team based approach to health care, under the supervision of a physician is the gold standard of care and there is no need to changed that requirement for psychiatric nurse mental health clinical specialists.

Any consideration of independent practice for psychiatric nurse mental health clinical specialists must address the lack of public protections required of nursing. Nurse practitioners are not subject to the public protections the legislature has created for the practice of medicine by physicians. Nurse practitioners do not have profiles listing their education, residency, specialties and history of discipline, criminal convictions or malpractice payments. They are not required to have professional liability coverage. They are not subject to mandatory continuing education requirements in specific areas as are physicians. They do not have requirements regarding electronic medical records and a host of other legislative mandates which apply to physicians.

The MMS urges individual legislators to consider the benefits to the public at large in dismantling the Massachusetts system of integrating psychiatric nurse mental health clinical specialists into comprehensive health care teams and replacing it with a legal framework for the independent practice of medicine by these practitioners without any corresponding requirement for additional education or increased professional certification or licensure requirements. 

The MMS urges the Committee on Mental Health, Substance Use and Recovery to reject H.1067 and S.1109 and to report the bills out of committee ought not to pass.

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