FTC, DOJ to Host Second Public Workshop on Examining U.S. Health Care Competition # 00049

Submission Number:
Heather McCoy
Integrative Headache Care, LLC.
Initiative Name:
FTC, DOJ to Host Second Public Workshop on Examining U.S. Health Care Competition
Matter Number:


I have been a licensed, board-certified Adult Nurse Practitioner practicing exclusively within the specialty of neuroscience for almost 15 years, the latter half with doctoral preparation. As I prepare to open my own private practice, I have been told by the state's largest private insurer (Banner Health) that my application for credentialing as an in-network provider would be denied unless I had a "supervising physician". Although I explained that the State of Arizona does not require this sort of relationship, they stated that this was discussed by their board of directors and thus decided that independent NP practices were not eligible for credentialing. So, in order for me to even APPLY to participate as an in-network provider, I would have to engage in a practice relationship with another equally-autonomous provider, a professional relationship that is not defined, authorized, or regulated by any practice authority. Of course, other NPs seeking enpanelment have been told the same. Another large insurer (Blue Cross Blue Shield AZ) offered me participation if I accepted a contract for reimbursement at 40% less than their usual physician reimbursement rates for the same service(s) rendered, again, indicating this was a "standard contract offeren to NPs in private practice". How can that be permitted? As an independent clinician, I have the same expenses, carry the same malpractice insurance, prescribe the same diagnostics, treatments, etc., and since I have a doctoral degree that included a 2,000-hr clinical residency, in many cases, I have the same length of post-secondary education (8 yrs). I maintain professional organization membership, maintain clinical compitency per state and professional organization standards and requirements, maintain unrestricted DEA privileges, and collaborate with the same professional colleagues (MDs, DOs, NPs, PAs, physical therapists, pharmacists, nurses, etc.). Yet these limitations make it very difficult, if not impossible, for patients to see me unless they are willing and able to pay out of pocket. Newly graduated MDs or heavily-sanctioned MDs do not face such barriers, yet I have nothing but years of practice excellence in my background. I look forward to your responses and hope for swift resolution for NPs such as myself who offer a valuable service to the communities we serve in nothing more than a fair practice environment.