Virginia Regulatory Town Hall
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Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
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6/19/20  3:36 pm
Commenter: Heather Lounsbury, MD

ER Utilization Program Failure
 

I strongly oppose implementation of the Emergency Utilization Program. Decreasing payment to $14.98 for the majority of the diagnoses I see and make every shift I work in the Emergency Department (ED) will negatively impact the ability of hospitals to care for patients. Hospitals will not be able to stay open and function with this substantial decrease in payment for these diagnoses. ED's must by federal law see all patients no matter what their complaint, ability to pay/insurance status, or time of day/day of the year. It is not acceptable to redirect patients to their primary care provider (PCP), if they happen to have one, or refuse to see them because they have a poorly reimbursing insurance. Often, it is also impossible to predict just based on their initial complaint if they will have one of these "preventable conditions" or a true emergency until a full ED workup is done. These patients are often already disadvantaged in the medical system, and this has the potential to further decrease their access to care if hospitals close due to poor reimbursement. It also puts the onus on the patient to know if they are having a true emergency or if they have a condition better managed as an outpatient by their PCP. Lastly, some of these "preventable conditions" are ridiculous- for example, diabetic ketoacidosis (DKA) can be and often is life threatening and has many potential precipitating causes; it can not always be prevented by medication compliance and good PCP/patient cooperation/management. I implore you to reconsider this program and the actual downstream effects instead of the presumed goal which is to decrease ED visits when possible. This is far too overreaching for that goal alone and has many, many other side effects.

CommentID: 80965