Virginia Regulatory Town Hall
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Board of Medical Assistance Services
 
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6/16/20  12:00 pm
Commenter: Gary Kavit MD FACEP , Riverside Health System

Preventable ER Visit list is bad for Virginia ERs and bad for Virginians.
 

The decision to develop a list of final diagnosis that will be paid at a reduced rate is contrary  to all the work done over the years to ensure appropriate medical care to all patient's  through EMTALA  and the well established Prudent Layperson Standard.  patient should never be put in a position with your expected to self diagnosis and determine whether an  emergency condition exists.   I believe this has been supported by recent actions by CMS through their guidance which obligates  state Medicaid  programs and manage care organizations to reimbursed doctors and hospitals for the delivery of emergency care based on presenting symptoms only.  These organizations have previously been given guidance by CMS to not use diagnosis list.

  This decision by Virginia Medicaid threatened the delivery of Healthcare to Virginians .  It will certainly weaken Urban and rural hospitals that Ca higher percentage of Medicaid patients.   These hospitals have already taken a significant negative financial impact secondary to COVID-19.  Emergency department volumes  have been down as much as closed to 50%.  This on top of decreased and patient volumes and cancelling of elective surgeries has put many hospitals in significant financial jeopardy.  Many of these hospitals did not receive significant Federal assistance because although they had significant decrease in patient volumes they may not have taking care of many COVID-19  patient's. 

It is ridiculous to believe that a final diagnosis is reflective of the time and effort spent on working through a differential diagnosis.  It is also an insult to the COVID-19 front line workers in emergency departments across the state, that part of the fix for State financial issues is to de-value their work.

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