THE VALUED VOICE

At the Feb. 16 Medical Examining Board (MEB) meeting, Department of Safety and Professional Services (DSPS) staff informed the MEB that their economic impact analysis of a draft proposed Medical Examining Board rule creating new chaperone duties for physical examinations by physicians would result in additional workforce costs of $55m annually in Wisconsin. As a result, the MEB began an effort to develop new rule language that would significantly reduce implementation costs. By law, an agency may not promulgate a rule that has implementation costs greater than $10 million over a two-year period.
 
The economic impact analysis by DSPS was largely informed by an advocacy effort by WHA to submit estimated workforce impacts and costs to the MEB in November 2021 on the draft rule. Working with WHA, a group of WHA members submitted its own comments as part of the MEB’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 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 WHA Senior Vice President of Workforce and Clinical Practice Ann Zenk in a November comment letter to the MEB. “It is important to note that Wisconsin and the United States are currently experiencing severe health care workforce challenges. Creating an additional widespread need for ancillary health care staff to provide the contemplated chaperone services will further exacerbate health care workforce shortages.”
 
WHA also noted in its November comment letter that the rule could be revised to drastically reduce its staffing and cost impact and offered to work 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.”