The Massachusetts Medical Society (MMS) wishes to be recorded in opposition to H.1867 and S.1330. These identical bills would allow nurse practitioners to practice independently, without the supervision of a physician, to order and interpret tests, prescribe controlled substances, and to order and evaluate treatment and therapeutic options. The MMS opposes increasing the scope of practice for nurse practitioners without any corresponding increase in education or training standards, or policies/regulations to ensure quality of care and patient safety. Passage of this bill without such provisions could jeopardize the high quality of health care provided to citizens of the Commonwealth through the current statutory framework.
The MMS believes that the physician led team-based care model 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, in many cases, post-residency fellowships, provide them with unique expertise and qualifications to manage care for the sickest, most complex patients. Surveys indicate that patients prefer health care teams led by physicians when care becomes complex and as patients age. The MMS supports H.1862, An Act to Promote Team Based Health Care, as a model for cooperative, integrated health care. MMS supports the current regulatory structure which allows autonomy for nurse practitioners and only requires mutually develop prescribing guidelines to ensure that proper collaboration is promoted for certain care. There are no requirements for co-signing of prescriptions or co-location of physician and nurse practitioner.
Proponents of this legislation contend that it will save money. While the MMS shares the Legislature’s commitment to finding solutions to the growing costs of health care in Massachusetts, we disagree that this legislation is an effective means to address costs. While nurse practitioners and other advanced practice nurses may be reimbursed at slightly lower rates, studies have shown that their increased utilization, referral patterns, and hospitalization rates often offset savings that might have resulted from the reduced price.
The MMS is concerned that this proposal could instead promote a two-tiered medical system whereby patients seeing physicians would be benefit from of a panoply of laws and regulations assuring the quality of care provided, whereas none of the same protections would apply to care provided by nurse practitioners, or other non-physician providers. The legislature, in fulfilling its duty to protect patients of the Commonwealth, has over many years 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. Specifically, the Medical Society points to the statutory requirement that all physician complete a two or three year medical residency, to the continuing medical education requirements, and to the online physician profile as important means by which the legislature has acted in the name of patient protection and transparency. Patients cared for by independent nurse practitioners would not benefit from these same protections.
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 protections to patients cared for by independently practicing physicians. The most important patient safety protection that can be provided to patients is to ensure that all care meets the same high standard, regardless of whether it is provided by a physician, APRN, podiatrist, optometrist, etc. Therefore, the Board of Registration in Nursing would need similar expertise and resources to understand and uphold the medical standard of care provided by physicians – a standard which the Nursing Board does not current meet.
In conclusion, we hope these comments convey a willingness and desire to engage in further discussion of strategies to further cost containment and increased access to care, while also promoting patient safety and quality for patients of the Commonwealth. While those discussions take place, we urge the Public Health Committee to reject H.1867/S.1330.
