Virginia Regulatory Town Hall
Department of Health Professions
Board of Nursing
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5/3/18  12:45 pm
Commenter: Norman M Jacobowitz, PMHNP-BC

HB793 / Burden of Proof / Expense

Thank you for the opportunity to submit public comments. Please note that I have 8 years of experience providing very competent care to thousands of patients in inpatient and outpatient psychiatry. I currently pay $400 per month to my collaborating physician, $4800.00 per year. This inherently limits the degree of sliding-scale fees I can charge to my indigent clients, of whom there are many. In addition, it limits my ability to take VA DMAS (Medicaid) patients. 

I respectfully request that the Board keep these factors in mind when promulgating rules for HB793 implementation:

  • Keep the process as paperless and inexpensive as possible, something that could be completed in a matter of minutes on your existing website;
  • Use the most liberal or open standard you can in regards to what constitutes evidence of 5 years of practice;
  • Make it clear in any forms you create for physician attestation that there is NO liability ascribed to the signing/attesting physician;
  • Impose no extra limitations, rules or other barriers in the regulations that would slow or impede NPs from qualifying; and
  • Finally, please always remember that there is no evidence whatsoever that NPs are any less competent in our care nor are we any more likely to cause patient harm than licensed physicians.

Physicians in all states have always been opposed to open access to NPs, strictly out of risks to their financial monopolies over caring for patients. 

Therefore, it is in the rational self-interest of the Virginia Boards of Medicine and Nursing to make rules for HB793 as open and easy as possible for qualified NPs to comply with as quickly as possible with the least amount of expense or burdensome efforts.

Thank you and feel free to contact me if you request more information.

CommentID: 65282