Public comment can have major impact on state rule-making. An MDHHS press release on September 29, 2023 announced a public comment period to begin October 6.
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CON certification exists purely to limit startups. It has nothing to do with licensing, competence, or quality of care.
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The Michigan Department of Health and Human Services is holding a public comment period for Certificate of Need (CON) Review Standards starting October 6, 2023 and continuing through Friday, October 20, 2023 at 5:00 P.M.
This public comment period is to receive written testimony on what, if any, changes need to be made and on the need for continued regulation or deregulation of each of the below listed CON Review Standards that are scheduled for review in 2024:
- Bone Marrow Transplantation Services
- Heart/Lung and Liver Transplantation Services
- Magnetic Resonance Imaging (MRI) Services
- Psychiatric Beds and Services
Please submit written comments no later than 5:00 P.M., Friday, October 20, 2023.
Comments may be submitted by sending an email to the following email address: MDHHS-ConWebTeam@michigan.gov. If you plan to comment on multiple standards, please send separate emails to comment on each standard.
The notice of the public comment period can be found on the 2023 CON Meetings Page.
The current CON Review Standards are here.
Some talking points from an MHF article in 2022:
Nationwide evidence for repeal is growing. However, the Michigan Hospital Association advocates to retain the veto power MDHHS and industry insiders enjoy over new local hospital and psychiatric beds, MRIs, and more.
The state bureaucracy is understandably reluctant to kill the golden goose. Millions of dollars in fees is perfectly good money, after all. The bigger the project, the more revenue for the General Fund.
CON protects profits and can leave patients unserved.
Kentucky had a great example of CON protectionism going - until it was recently struck down in court.
https://mihealthfreedom.org/community/postid/372/
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