June 29, 2017

On behalf of OrthoVirginia, I would like to provide public comment on the periodic review of the State Medical Facilities Plan and Certificate of Public Need. We believe these regulations are burdensome and serve as a barrier to patients receiving high-quality, affordable health care in the Commonwealth. The SMFP is required to be updated at least every four years, and the last update was eight years ago in 2009.

Virginia COPN laws should be significantly reformed and replaced with a licensing program that permits providers to offer the services their patients need, as long as they meet quality of care standards and provide charity care services.

The regulations of the COPN laws limit what kinds of services we can offer our patients. If our patients would benefit from Magnetic Resonance Imaging (MRI) services provided in our office, we must apply for permission to do so. Our application may be rejected based on outdated requirements and our patients will never benefit from this service. As a result, we would have to refer patients to a hospital to receive a MRI. This can be both inconvenient and will cost more money for our patients. At OrthoVirginia, we can offer this service for approximately a third of what a hospital will charge. At the end of the day, our patients are paying more out-of-pocket because of COPN regulations.

The COPN regulations are outdated and no longer appropriate for our evolved health care system in Virginia. Patients and small businesses in the Commonwealth are negatively impacted by these regulations. We hope you will consider our comments during your review. Thank you for the opportunity to provide comment.

Sincerely

Michael W. Mariscalco, MD