Announcement of Public Workshop, "Examining Health Care Competition" ("Health Care Workshop") Project No. P13-1207 #00100

Submission Number:
Victoria Tan
New York
Initiative Name:
Announcement of Public Workshop, "Examining Health Care Competition" ("Health Care Workshop") Project No. P13-1207
Disclaimer: 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. Retail clinics are growing in popularity because of its convenience, accessibility, fast service, low costs, and transparent pricing. The main reasons for visit reported by satisfied patients include acute and minor conditions, primary care, and preventative care. Patients want an expansion of services to include chronic conditions, but it is unclear if retail clinics are working to provide them. Commercial barriers such as costs of services and regulatory barriers such as government regulations restrict the use and proliferation of retail clinics. State governments should modify regulations to allow nurse practitioners more autonomy and broader scope-of-practice in retail clinics. Regulations vary widely between different states, such that some allow nurse practitioners to practice independently while others require physician supervision. The preferred solution is to have state governments expand the scope-of-practice of nurse practitioners by increasing the number of services they can provide beyond primary and preventative care, and allowing them to prescribe and practice independently. To protect against fraud and ensure quality of care, state departments in charge of enforcement and inspection should be allowed to maintain strict licensure authorization. Retail clinics can expand the number of services they provide because they can employ more nurse practitioners to assume extra duties and responsibilities. This will be feasible for retail clinics because they can save on costs since the salaries of nurse practitioners is generally less than that of physicians. This will also be feasible for state governments since most states currently already support independent practices of nurse practitioners while a few states still require physician oversight. The different state governments should collectively consider adopting the following guidelines. Allow nurse practitioners to practice without physician supervision in retail clinics, especially in areas where there is a shortage of primary care providers. Recommend that nurse practitioners seek physician approval over drug prescriptions in retail clinics to prevent overuse of medications. Increase the number of services that nurse practitioners could provide to include emergency or chronic care. Recommend that nurse practitioners who wish to do advanced clinical procedures independently should provide proof of additional training and experience. Require that nurse practitioners provide any necessary follow-up appointments to ensure continuity of care. Monitor patient satisfaction to ensure quality of services by setting up a national rating system of nurse practitioners. Record and handle seriously any reports of malpractice liability claims to establish safety and ethical standards. Require evidence-based practice protocols to be put in place to guarantee that hired nurse practitioners have the knowledge and skills to practice independently. By allowing nurse practitioners to independently practice to their fullest extent, consumers will be protected because retail clinics will be able to meet the increased demand of certain services and competition will be protected because retail clinics can impose competitive fair prices on their services. Retail clinics can then become the disruptive innovation they have claimed to be in the health care delivery system.