Dear Administrator Verma,
Deeming non-physicians to be essentially equal in training and experience to physicians amounts to a dangerous experiment on American patients. It is improper and unethical for the federal government to be making such decisions regarding the scope of practice of medical professionals.
I have spent over 40 years as a complex litigation specialist. Handling over 35,000 malpractice claims. It seems the law of unintended consequences is at play. Currently the “Captain of the Ship” doctrine limits liability to allied health personnel. It also limits professional and legal liability costs. Placing nurse practitioners and Physician assistants on par will indeed lead to greater claim frequency and increased legal costs. Rates for all providers will increase. In fact underwriters will increase offices with PA’s and NP’s. We could see malpractice costs for internal medicine practices rise from $1-3,000 to $9-12,000 per allied health professional .
We saw the law of unintended consequences occur with EHR and once down that “rabbit hole” there is no return. There is both a patient and physician expense that has not been calculated.
Likewise it is irrational and counterproductive to pay a minimally trained person the same as a highly trained, experienced person. If the reimbursement is the same for poor quality as for good quality, but the poor quality costs less to provide, the entities that degrade quality have a competitive economic advantage. Medicare’s existing price controls are already impeding patient access to high quality care and should not be exacerbated by additional flawed policies that further disregard important differences between practitioners.
The bottom line is that patients’ lives are at risk. The federal government should follow a policy of “first do no harm.” It violates this principle to impose top-down edicts declaring that non-physicians are qualified to practice medicine. I urge the federal government to reject such policies.
President, Edge Professional Liability Services https://edgepro.net/