WHA submitted comments to the Medical Examining Board last week raising concerns about a proposed rule creating new chaperone duties for physical examinations by physicians.
“WHA has received concerns that as currently drafted, the proposed rule would significantly exacerbate current critical health care workforce shortage challenges, and substantially increase health care staffing costs assuming necessary staff could even be hired to fill the new staffing positions contemplated by the rule,” wrote Ann Zenk, WHA Senior Vice President, Workforce & Clinical Practice.
“Based on information received from our members, the proposed rule as drafted would likely result in the need for several hundred new staff statewide with new statewide annual staffing costs of several million dollars,” said Zenk in the comment letter.
“It is important to note that Wisconsin and the United States are currently experiencing severe health care workforce challenges,” wrote Zenk. “Creating an additional widespread need for ancillary health care staff to provide the contemplated chaperone services will further exacerbate health care workforce shortages.”
WHA’s comment letter was submitted as part of the economic impact analysis stage of rulemaking. Under Wisconsin statute, agencies are required to conduct an economic impact analysis, including gathering comments from the private sector, on their proposed rules. Following completion of an economic impact analysis, the Medical Examining Board must have an additional public hearing and public comment period on the whole of the rule.
Working with WHA, a group of WHA members also submitted their own comments as part of the Medical Examining Board’s 14-day economic impact comment period. Altogether, that sample size alone indicated annual costs in the tens of millions of dollars and hundreds of new employees to implement the proposed rule.
WHA also noted in its comment letter that the rule could be revised to drastically reduce its staffing and cost impact, and welcomed working with the Board to discuss potential modifications.
“We believe that the draft proposed rule could be revised to address the Board’s goals and intents more precisely, and address much of the staffing and cost concerns,” wrote Zenk. “As the Board develops its economic impact analysis and moves into the next steps in the rulemaking process, WHA welcomes further discussion with the Board, including potential modifications of the proposed rule.”
At its November meeting, the Medical Examining Board noted that they had received several comment letters on the economic impact analysis, and the Board took action to extend the original 14-day economic impact comment period to January 3, 2022.
If you have any questions about the proposed rule or the economic impact comment period, please contact WHA Senior Vice President Workforce & Clinical Practice Ann Zenk or WHA General Counsel Matthew Stanford.