Dear Mr. Bodin:

On behalf of OrthoVirginia, I would like to provide public comment on the periodic review of the Virginia Medical Care Facilities Certificate of Public Need (COPN) Rules and Regulations, 12VAC5-220. We believe these regulations are burdensome and serve as a barrier to patients receiving high-quality, affordable health care in the Commonwealth.

These regulations limit what kinds of services we can offer our patients. If we see a need with our patients to have a Magnetic Resonance Imaging (MRI) machine in our office, we must apply for permission to do so. Our application may be rejected based on outdated requirements and our patients will never benefit from this service. As a result, we would have to refer patients to a hospital to receive a MRI. This can be both inconvenient and will cost more money for our patients. At OrthoVirginia, we can offer this service for approximately a third of what a hospital will charge. At the end of the day, our patients are paying more out-of-pocket because of COPN regulations.

It is my understanding that the periodic review also includes a small business impact review. Physician practices are small businesses and are directly harmed by COPN regulations. They limit our ability to grow our businesses and expand the services offered. If a business does decide to apply for a COPN, they will go through an extremely costly and lengthy process. Many businesses cannot afford to take this risk and do not even attempt.

The COPN regulations are outdated and no longer appropriate for our evolved health care system in Virginia. Patients and small businesses in the Commonwealth are negatively impacted by these regulations. We hope you will consider our comments during your review. Thank you for the opportunity to provide comment.

Sincerely,

William Andrews, MD

OrthoVirginia