Testimony in Opposition to H.2452/S.658 Before the Committee on Health Care Financing

The Massachusetts Medical Society (MMS) wishes to be recorded in opposition to H.2452/S.658, “An act to remove the restrictions on the licenses of CRNAs.  These identical bills would allow certified registered nurse anesthetists (“CRNA”) to practice independently.  Specifically, the bills would allow CRNAs to order and interpret tests, and to prescribe, dispense, distribute and conduct research on controlled substances – without any physician supervision. 

Anesthesia is the practice of medicine – critical care medicine. It is often the patient’s medical problems that convey greatest risk during even routine surgery, and proper recognition and treatment of these medical conditions are even more important in complex surgeries. CRNAs’ education and clinical training does not include any significant time studying and training in the diagnosis and treatment of these conditions. Physician anesthesiologists have at least 12,000 – 16,000 hours of supervised clinical patient care during training, while CRNAs have a median of 1,650 hours of supervised clinical experience. Under this legislation a CRNAs with only 1,650 hours of clinical training would be able to practice independently without any physician supervision or oversight.

The MMS considers this an issue of patient safety. If passed, a CRNA would no longer be required to ensure a physician is immediately available to assist them in case of emergency such as cardiac standstill or cardiac arrhythmia. In an emergency, where seconds count, having a physician anesthesiologist or other qualified physician immediately available, working with and overseeing the NA reduces risk and ensures the safe delivery of quality anesthesia care.  

The MMS continues to support the physician-led, team-based model as the gold standard of care. Physician led team-based care promotes integrated, coordinated care that utilizes all appropriate health care professionals while ensuring that physicians are available for consultation or collaboration when necessary to promote the highest quality and safety of care for patients. Physicians’ extensive medical education, required medical residencies, and often post-residency fellowships provide them with unique expertise and qualifications to manage care for the sickest, most complex patients. Moreover, surveys indicate that patients prefer health care teams led by physicians when care becomes complex and as patients age. 

The legislature, in fulfilling its duty to protect patients of the Commonwealth, has established a thoughtful, patient-focused framework of policies and statutory requirements that apply to physicians in light of their ability to independently provide medical care. Legislation that authorizes new independent practice for any health care practitioners must include the same patient protections. Specifically, the Medical Society points to the medical residency requirement, to the 100 credit/hour per license cycle continuing medical education requirement, and to the online physician profile as important means by which the legislature has acted in the name of patient protection and transparency. Additionally, the Board of Registration in Medicine, with its unparalleled requirements and thoroughness in the licensure process, and through the unmatched sophistication and resources of its investigatory unit, also provides important patient protections to independently practicing physicians. The MMS believes that these and other enhancements should be considered before allowing for the independent practice of non-physician practitioners.   

The Medical Society urges the Committee on Health Care Financing to reject H.2452/S.658.

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