Ms. Marissa Levine, MD, MPH                                                                                       March 27, 2017

State Health Commissioner

Virginia Department of Health

109 Governor Street

Richmond, Virginia 2321

RE: Periodic Review of 12 VAC 5 ? 408 Certificate of Quality Assurance of Managed Care Health Insurance Plan (MCHIP) Licensees

Dear Dr. Levine:

The Medical Society of Virginia (MSV) respectfully submits comments to amend 12 VAC 5- 408 of the Code of Virginia.  MSV represents nearly 11,000 physician, medical student and physician assistant members and aims to make Virginia the best place to practice and receive medical care. 

MSV’s proposed amendments aim to address physician concerns that the current process diverts time and resources away from patient care.   For MSV’s comments related to the current periodic review of the Certificate of Quality Assurance of MCHIP Licensees, MSV refers the department to comments submitted previously as part of a petition for rulemaking on January 11, 2016 regarding 12 VAC 5-408 of the Virginia Code, which have been attached to a separate email to Erik Bodin. 

Thank you for your consideration of our proposed amendments.  MSV appreciates the department’s continued work to ensure the credentialing process leads to enhanced quality and patient outcomes.  Please see a separate email to Erik Bodin for all relevant attachments.  

Sincerely,

Lauren Bates Rowe

Assistant Vice President of Health Policy

CC: Erik Bodin, Director Office of Licensure and Certification, VDH

Melina Davis-Martin, Executive Vice President, MSV

Scott Johnson, General Counsel, MSV

Ralston King, Assistant Vice President of Government Affairs, MSV

Julie Galloway, Health Policy Analyst, MSV