Virginia Regulatory Town Hall
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Department of Medical Assistance Services
 
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Board of Medical Assistance Services
 
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6/19/20  3:55 pm
Commenter: Daniel Hawkins MD, UVA

DMAS: Impact of the ER Utilization Program
 

The proposed changes to billing, namely "preventable" visit codes being limited to $14.98, are dangerous.  They will hurt patients.

A cursory review of this list includes multiple diagnosis that can lead to death or disability if neglected for even a short time.  Here is a small selection of some egregious offenders, although many on this list are equally dangerous.

Hypoglycemia or low blood sugar: this is an immediately life threatening diagnosis that often goes unrecognized and can lead to death within minutes.  Although the most common causes are benign, I do not think it is reasonable to expect lay persons to investigate and know the difference if a patient develops diaphoresis , confusion, or experiences syncope.  What is more, on further investigation one often finds a secondary cause such as inadequate knowledge of their medications or underlying infection.  This is absolutely a diagnosis that can require an ED visit for a prudent layperson.  

"Pain in left knee" : this patient may require a workup for a septic joint, and a miss on this diagnosis can lead to permanent disability, joint replacement, sepsis, or death.  It could also easily represent a deep venous thrombosis or a blood clot of the leg which again can lead to a pulmonary embolism or blood clot in the lung, which can lead to death, disability, and irreversible injury to the heart and lungs.

"Cellulitis of the groin" can easily turn into Fournier's gangrene (a necrotizing or frequently misnamed "flesh eating" bacterial infection), sepsis, and death in the wrong patient.  It is insane to expect that a lay person can see a red, obviously infected and painful area on their genitals and know the distinguishing features to know if this is a life threatening diagnosis or merely a painful and embarrassing one. 

Implementing these changes will hurt patients.  It will hurt them with delays in care, delays in diagnosis, and increased wait times.   If hospitals and physicians are not compensated appropriately, we cannot keep the lights on, and we cannot afford to have adequate staffing.  Hospitals, physicians, nurses and all members of the healthcare community and economy are already hurting right now.  The proposed changes to billing will result in closure or understaffing of multiple critical access hospitals given these existing stressors.

The ED is often the only point of access for those who do not have the ability to seek care elsewhere.  The people who will be hurt the most by these changes will not be the rich, the privileged or the medically literate patients who know how to care for themselves.  It will be the poor, the marginalized, and the homeless for whom we are the last haven of safety.   It will be the working mother who can't get her feverish child to the pediatrician, the homeless man who can't afford his co-pay for a primary care visit or for his antibiotics, and the newly ill who do not yet understand their medical conditions.

You must reconsider the proposed changes.  They are unsafe, unfair, and unconscionable. 

CommentID: 80980