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.
