I appreciate that there is value to having a statewide COPN, but acknowledge the arguments made by those opposed to COPN.   The common theme to opposition seems be a desire for a more free market economy approach.  Healthcare is not, never has been, and never will be a free market economy.  Even so, I could believe that the arguments put forth by those opposed to COPN aren't self-motivated if they made one change to their proposal.  If they would agree to prevent any ordering clinician from profiting from the imaging he/she orders, I could support COPN reform.  

The clinicians ordering these studies will greatly impact where the patients go to get their imaging and the clinicians will direct them to the imaging they own.   There is no shortage of peer reviewed studies showing that clinicians who can profit from advanced imaging not only order more advanced imaging, they also order more studies that are normal - they are less discrimnate about ordering CT/MRs when they can profit from them.  That's more money, and more patient radiation,  for more studies that are normal.   As we enter an era of value over volume and as we move to population health management, allowing ordering to clinicians to profit by over-ordering advanced imaging seems as foolish as it is counterproductive.

Please eliminate the State Medical Facilities Plan. This will help to service the peoples needs and give them qoality care for everyone. Type over this text and enter your comments here. 

In the field of neonatology, regionalization of care has been shown to improve care - both morbidity and mortality. Without COPN requirements in place, the number of NICUs has expanded tremendously leading to deregionalization across the US. Both the American Academy of Pediatrics and the March of Dimes as well as other leading neonatal/perinatal organizations have continued to advocate for regionalization of care. In order to ensure the best possible outcomes for premature and critically ill infants, COPN regulations should remain in place.

The goal of both health policy and health care is to provide quality care to the patient. That is well-described in the six domains put forth by the IOM: Safe, Effective, Patient-centered, Timely, Efficient and Equitable. The current health care system (which includes the current SMFP) sometimes fails to meet those goals. However, how would modification achieve it better? Virginia already experiences an imbalance of over accessibility and over utilization in some areas and inaccessibility in others. Additional healthcare facilities in an area routinely demonstrate an increase in utilization and cost without correlating improvements in quality. Also, clinical and information technology is allowing healthcare to become more virtual and patient-centered - the right care and the right time with less need for facilities.

With 25 years in healthcare quality measurement and policy, I am a strong advocate of public reporting of quality as a means for health care organizations to be accountable to the public. Health care organizations strive even harder for quality when there performance is public. If the SMFP were modified, it should be done with a requirement that the facilities report nationally endorsed quality and safety metrics. These quality metrics should be available at the facility level, include outcomes measures (not just process measures), be current, be available from the main web page of the organization, and be provided to the public upon request (phone and electronic message). In addition, the amount of charity care in terms of numbers of patients by age range should be as publicly accessible as the quality and safety metrics.

Health care delivery is changing continually. It is difficult for the SMFP to anticipate the needs for health care facilities into the future. It is not hard to imagine innovative health organization might improve upon the plan. However, health care organizations should be held publicly accountable through publicly available quality, safety and charity care reporting. There are few, if any, health care organizations in Virginia that publicly provide current outcomes measures for the care they provide.

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

William C. Andrews, Jr., MD, FAOA

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

John W. Barnard, Jr., MD

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

Peter A. Caprise, Jr., MD

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

Kristopher D. Collins, MD

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

David G. Cox, DPM

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 J. Diminick, MD

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

Omar Elkhamra, MD

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

H.C. Eschenroeder, Jr., MD

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

Gautham Gondi, MD

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

Joyce L. Huerta, MD

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

Eric R. Kenny

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

Drew E. Kiernan, MD

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

Edward J. Lewis, MD

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

Sara Ashley McCowen-Botterill, MD

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

Joseph Orchowski, MD, FAOA

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

John R. Prahinski, MD

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

Ian R. Smithson, MD

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

Robert W. Sydnor, MD

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

Joseph H. Wombwell, MD

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

George Aguiar, MD

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

Christopher C. Annunziata, MD

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

Eva Umoh Asomugha, MD

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

Anthony L. Avery, MD

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

Gordon L. Avery, MD

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

Anne M. Bielamowicz, MD

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

Ronald C. Childs, MD

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

Nancy R. Couleman, MD

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

Alexander S. Croog, MD

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

Brian P. Gladnick, MD

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

Mark C. Hartley, MD

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

Candice P. Holden, MD

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

Steven S. Hughes, MD

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

Ben W. Kittredge, IV, MD

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

Thomas J. Klein, MD

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

Daniel K. Laino, MD

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

H. Edward Lane, III, MD

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

Keith W. Lawhorn, MD

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

Kevin C. Lutta, MD

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

Mark P. Madden, MD

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

Thomas A. Martinelli, MD

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

B. Thomas Mazahery, MD

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

John P. McConnell, MD

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

Mark R. McMahon, MD

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

William R. Mook, MD

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

David J. Novak, MD

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

D. Andrew Parker, MD