Dear DMAS Director and Chair of Utilization committee, I was puzzled and disappointed to learn that DMAS is introducing a new rule of payment for ER services based on a exit or departing diagnosis, rather than the reason for seeking emergency care and initial "rule out" diagnosis.  How can a patient or even a provider tell ahead of time whether the final diagnosis will meet criteria for ER services? Such "rear view mirror" approaches are inappropriate in assessing, patients who present to the ER. The ER provider is under a moral, professional and ethical and legal obligation to provide all appropriate assessment and care for patients presenting to the ER. No short cuts are to be taken. consider the following examples: a frequent flier patient with chest discomfort, a chronically suicidal patient, a patient who experience aura heralding a seizure that may or may not happen. By taking the rear view mirror approach based on prior visits, there is a likelihood such patients will receive inadequate care and can/will be harmed. 

I ask that DMAS not implement this new rule. 

If utilization and cost savings are the goal, I suggest DMAS strengthen the availability and accessibility of outpatient providers and office practitioners, case managers, navigators, etc especially after-hours, weekends, and holidays. 

Thank you for considering.