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  6:23 pm
Commenter: Russell Goldstein, MD - Alteon Health

ER Utilization Program is Dangerous and Bad for Virginians
 

As an emergency medicine physician practicing in Virginia, I am deeply troubled by the DMAS ER Utilization Program proposal.  One of the core services provided by the emergency department is to determine what symptoms represent a life-threatening emergency and which do not.  There is no way for a patient to know whether their chest pain is a sign of a deadly heart attack or a more benign condition.  There is usually no way for even the physician to know until a series of tests are run in the ER.  This is just one example of countless others.  Reimbursement should therefore be based on the complexity and high stakes of the necessary work-up, not on a pre-determined list of diagnoses.  This would ultimately put the onus on patients to determine whether their symptoms require emergency evaluation and therefore gamble with their lives.  

At a time when increasing health and social equity is in the spotlight, this proposal would lead to the exact opposite.  With such a dramatic reduction in reimbursement, hospitals and emergency rooms would not be able to maintain adequate levels of staffing or provide sufficient resources to their communities.  This would disproportionately affect areas that care for underrepresented minorities.  With so much potential for progress across the nation right now, it saddens me to think what a tremendous step backwards this proposal would cause.

Furthermore, many of the diagnoses included on the "Preventable ER Visits" list include true life-threatening emergencies.  Examples include diabetic ketoacidosis, status asthmaticus, and acute abdomen.  There is no reasonable alternative to the ER for treatment of these conditions.  When present, they require immediate intervention and stabilization and, frequently, admission to an intensive care unit.  Other conditions on the list such as pneumonia, cellulitis, and hypoglycemia can easily progress to becoming life threatening and often require hospitalization or ICU admission.

The COVID-19 pandemic has shown that the vast majority of emergency medicine providers across our state are willing to risk everything up through their own health and lives to care for our patients.   We simply ask that DMAS and our legislators develop policies that are fair, reasonable, and allow us to remain viable to continue caring for the people of our communities.  Thank you.  

CommentID: 81054