Testimony on Proposed Draft Regulation 958 CMR 6.00, Registration of Provider Organizations

Before the Care Delivery and Payment System Reform Committee of the Mass. Health Policy Commission

Testimony from Ronald W. Dunlap, MD, President of the Massachusetts Medical Society

On behalf of the over 24,000 physicians, residents, and students, I thank you for the opportunity to provide comment on the proposed provider registration regulations (.pdf, 13 pages). I want to thank Dr. Altman for his comments when the Commission reviewed the proposed regulations, at which time he urged the drafters to weigh these requirements on balance with the administrative burden they will create. Dr. Altman could not have been more on target.

In that same vein, we would ask that these regulations be viewed in the context of all of the administrative requirements imposed by Chapter 224 of the Acts of 2012. These requirements include DOI Risk Bearing Provider Organization regulations, Electronic Medical Record requirements as a condition of licensure and Price Transparency to name a few.

Collectively, these requirements increase administrative demands, add costs to the practice of medicine, and to the health care system as a whole. They will take time away from direct patient care and drive small to midsize practices to seek alignment with larger entities that have the capacity to fulfill the requirements, potentially causing further consolidations in the healthcare market.

Likewise, while we acknowledge the reporting requirements and timing that are stipulated in statute, there appears to be overlap in the information that is required to be reported to various agencies. Some are within the same executive offices and others across agencies and departments. We believe this overlap may lead to the same results. We urge cooperation and collaboration between and among the agencies to aid in elimination of this duplication.

With regard to the specifics, we would urge you to refine the broad nature of the information contained in Section 6.05(8) as it suggests a one size, monolithic organizational structure in the registered physician groups. Furthermore, we are concerned that making NPI numbers necessary goes beyond the statutory requirements. Likewise, we would urge the commission to be sensitive to privacy and competitive concerns as they relate to individual physician information. 

We would also seek clarity on whom must register. Section 6.04 (1) states that both provider and provider organization must register,  yet Chapter 224 appears to only require the provider organization to register. The notion of reporting utilization by major service category seems daunting in its underlying definition with the details to be contained in the Data Submission Manual. This manual may in and of itself constitute an additional set of administrative burdens . We urge careful consideration and understanding of what is involved in collecting and submitting this information. 

Finally, we join with Atrius Health in strongly suggesting that the HPC only collect baseline information for the first several years, to minimize administrative burdens and the disruption of patient care.

The Medical Society remains committed to working with HPC to limit the growth of spending in health care.

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