... BY YOUR DEPARTMENT OF JUSTICE'S ANTITRUST DIVISION, BY YOUR DEPARTMENT OF HEALTH AND HUMAN SERVICES, AND BY YOUR FEDERAL TRADE COMMISSION, if online, then before May 6, 2024.
These Government agencies want to hear from you. We can submit our comments online or mail them. If we submit our comments online, we can use the Federal eRulemaking Portal at www.regulations.gov. Whether we submit our comments online or by mail, they want us to identify our comments by Docket No. ATR 102. (On the Federal Trade Commission's website, I noticed this number as well on the FTC website: Document ID FTC-2024-0022-0001. When I leave my comments online at www.regulations.gov, as I intend to do, I will use the Docket No. ATR 102 like they ask for, but I just wanted you to know in advance what you will see if you send your comments through the FTC's website.)
These people want to hear from everyone who has a stake in Health Care in this nation. They want to hear from stakeholders, whether or not the stakeholders also hold shares in the companies that hold themselves out as providing you with Health Care in this country.
We will address different aspects of this Request for Information ("RFI") as time goes on, but that is not because the RFI is very long; it isn't very long. It is only 12 pages long (11 pages, really, because the 12th and last page is only a signature page and does not have any text to read on it). Rather, you and I will take our time together to look over the RFI because the information these agencies are looking for is huge.
For example, the agencies list out 5 questions they are interested in, 4 specific questions and one last overall question that asks if there is anything else we would like to address that we haven't already told them about.
We will start with their first question, and they ask us to "identify, where possible, the question numbers your comments are intended to address." Question 1 asks about Effects of Consolidation.
If you are a patient – and who isn't at one time or another – they want to know how a transaction that involved your health care providers like home-and community-based services, health systems, nursing homes or ambulatory surgical centers to name a few, affected in any way the providers' costs for you to obtain care, or ...
... costs of health insurance coverage, medical debt and access to charity care, quality of clinical or non-clinical care, quality of the patient’s experience, access to and denials of care, language access, types of goods and services offered, safety, utilization of services, drug utilization, staffing levels, mix of providers and medical support staff, practices regarding prior authorizations, other utilization management, or reimbursement strategies, referral practices, site of service for procedures, ease of access to providers, patient billing, collections, financial assistance practices, access to or sharing of patient information, differences in these areas in rural compared to urban settings, and differences in areas for marginalized patient populations, including differences by race, ethnicity, gender, sexual orientation, income level, disability, Tribal status, or citizenship status.
Think they left anything out? Please remember that these are only examples of what you can talk to them about; they want to hear your experiences with these things, not somebody else's experiences.
Whatever we do in leaving our comments to provide them with information, they want us to remember this very important thing:
DO NOT include sensitive or confidential information in the comments including: social security numbers, dates of birth, driver’s license numbers or other state identification numbers, financial account information, sensitive health information, or competitively sensitive information. Comments will be posted on the Internet and made available to the public (subject to exceptions such as for personal privacy information of persons other than the submitter).
TO BE CONTINUED .... Please read the disclaimer. ©2024 Dennis J. Wall. All rights reserved.
COMMENTS IN RESPONSE TO REQUEST FOR INFORMATION ... Continued.
This article continues from the article published earlier today sharing my Comments as examples of Responding to the federal government's Request For Information regarding our personal experiences with the consolidation of healthcare services in this country.
Turnover of professionals. Before consolidation, I observed that the nurses who assisted my caregiver tended to remain the same from visit to visit. Before consolidation, the nurses tended to be familiar with my chart on each successive visit, and in many cases had first-hand knowledge of what symptoms and conditions I may have presented in the past, with memories refreshed no doubt from my records including my chart. For example, I have made it a point to say when a nurse or a tech or whoever draws my blood, to say that as long as they keep talking to me, we're going to be all right, and they did. In fact, they remembered my saying that because they had heard it from me before, of course, even though my blood was not drawn regularly and still they remembered.
After consolidation, the nursing turnover was so great and often that the nurses did not know me or my chart, including my reaction to having my blood taken.
The patient portal. This innovation has been with us for years, but I do not recall it existing before my local family practitioners' office where I was a patient for some 25 years, consolidated with a private equity firm.
I resisted using the portal for a long time because I was used to my physicians contacting me, and not the other way around. I ended my resistance to the portal when the futility of resistance became obvious; after the portal went into effect, my physicians' office no longer telephone me to let me know such things as test results were ready. After consolidation and the portal took effect, I had to access their portal if I were going to know that test results, for example, were ready.
In my experience, the advent of the patient portal altered the relationship between doctor and patient. Before the portal arrived following consolidation with the private equity firm, the emphasis of my relationship with my physicians flowed from their office to me, I was the reason for their existence.
After the portal arrived following consolidation, the emphasis of that relationship flowed from me to their office and nothing, absolutely nothing including the test results example I have mentioned, could happen unless I, the patient, approached their office through the so-called patient portal and not otherwise. I learned this when I tried – unsuccessfully and often – to telephone..
Thank you for your consideration of my Comments.
Please read the disclaimer. ©2024 Dennis J. Wall. All rights reserved.
Posted by Dennis J. Wall on May 07, 2024 at 12:50 PM in Comments on Proposed Rules, Regulations and rules of administrative agencies. | Permalink | Comments (0)
Tags: #Comments, #HealthCareConsolidation, #PrivateEquity, #RequestForInformation