Announcement of Public Workshop, "Examining Health Care Competition" ("Health Care Workshop") Project No. P13-1207
I am a student at Columbia University. However, this comment to the Federal Trade Commission reflects my own personal opinions. This is not representative of the views of Columbia University or the Trustees of Columbia University. Reference Number: P131207 The lack of consistent and comprehensive oversight of retail clinics means that incentives for retail clinics are not necessarily set up to maximize the quality and value of healthcare provided, and could lead to duplicate care between retail clinics and traditional providers. Another conflict of interest that could be addressed by regulations is that retail clinics may have incentive to influence patients "to buy medications and other items at the facility where the clinic is located" (Takach, 2009). Spetz et al found that broadening the scope of nurse practitioners increases the cost saving ability of retail clinics, because nurse practitioners have been proven to provide the same quality of care as physicians, but at a lower salary. Additionally, Spetz et al found that "if state regulations limit the scope of their practice, NPs might not be able to fully meet the needs of patients in settings such as these clinics. This could make it more likely that patients have to seek subsequent treatment in traditional settings, producing an overall increase in costs" (Spetz, 2013). State legislatures could pass laws that broaden the scope of nurse practitioners to see patients and prescribe medications without oversight or approval by a physician, and the FTC could promote independence of the nurse practitioners. This is in line with the Institute of Medicine's recommendation that "all health care professionals be permitted to practice at the highest level of their knowledge" so that our healthcare system can meet the needs of all individuals (Spetz, 2013). This option enables multiple retailers to establish clinics in a market, and establish relationships with providers at their choosing. Research has also shown that visits to retail clinics result in prescriptions being filled more often than nonretail visits, but nurse practitioner independence "mitigates the number of prescriptions filled" (Spetz, 2013). If nurse practitioners have strong ties to local providers there is a risk that cost savings will not be realized because clinics will "simply serve as feeder systems for hospitals that either own or operate the clinics" (Tu, 2013). To eliminate this conflict of interest, the FTC should promote independently operating nurse practitioners. As the number of individuals with access to our healthcare system increases as a result of the Affordable Care Act, allowing nurse practitioners to provide broad services to patients could increase the ability of individuals to obtain the primary care they needed. Additionally, the convenient locations and operating hours of retail clinics could make it easier for individuals to get the treatments and medications they need in a timely manner. This could increase the ability of individuals to obtain the care they need to maintain good health, while reducing the cost of providing primary care services. Mehrotra, Ateev and Judith R. Lave. "Visits To Retail Clinics Grew Fourfold From 2007 To 2009, Although Their Share Of Overall Outpatient Visits Remains Low". Health Affairs. Vol. 31, No. 9, pp. 2123-2129. September 2012. Spetz. Joanne; Parente, Steven T.; Town, Robert J. and Dawn Bazarko. "Scope-Of-Practice Laws For Nurse Practitioners Limit Cost Savings That Can Be Achieved In Retail Clinics". Health Affairs. Vol. 32, No. 11, pp. 1977-1984. November 2013. Takach, Mary and Kathy Witgert. "Analysis of State Regulations and Policies Governing the Operation and Licensure of Retail Clinics". National Academy for State Health Policy. February 2009. Tu, Ha T. and Ellyn R. Boukus. "Despite Rapid Growth, Retail Clinic Use Remains Modest". HSC Research Brief. No. 29. November 2013.