| A | B | D | E | F | G | H | I | J | |
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1 | Timestamp | Name | Medical - Written Comments | ||||||
2 | 8/11/2025 22:26:31 | MV Medical | When do we admit ACA is not working for patients or providers. Patients are kept in the dark on most of medical matters and now billing has become more obsequious. It’s time to look for other solutions than insurance companies and pharmaceutical companies who overcharge and under serve their payers. | ||||||
3 | 8/12/2025 7:40:26 | John F Gibbons | Agree with the intent of this measure. Transparency and Knowledge of the consumer/citizenry is vital to an informed and engaged community. But, I must protest. This is yet another legislative safeguard = mandate placed on the shoulders of medical providers! I am 100% against. We have to find another mechanism to enact safeguards not just pushing it down to the lowest common denominator - where patient and providers meet. There are numerous courses of action I could suggest if needed. But think a whole of community approach would be best. I am not sure if there are any providers involved in writing this proposal, but I would have to guess there isn't or they are delusionally out of touch with rising challenges providers face on a day to day basis. We often forget that what we do is HARD and the HARD part of medicine is the actual art of medicine. This proposed messaging is an administrative issue, and should not be asked of the health care provider. PLEASE - stop forcing providers to enact these non medical measures. | ||||||
4 | 8/12/2025 9:53:16 | Sabrina Debra Trieff Frierson | As a surgeon, who has worked in a private group practice, employed, both as office based + taking ER/hospital call- and as hospital based-acute care surgeon, and as locum tenens, I believe the brunt of this should be placed upon the business managing side, whether it be the hospital associated employer, the clinic employer, the contracting physician-employer, and ultimately, if a physician chooses to run their own practice/business, then they would bare that responsibility. Doctors are not qualified for this job without additional training/ continuing education. Medical providers are not trained in this field and I personally feel things change so often and randomly, that it would be impossible to stay informed enough to accurately advise a patient of this information. As a patient advocate, after the first patient came back complaining to my partner, who thought they were doing a favor to the patient who came to the ER 3x for biliary colic, that they got an atrocious bill for the lap chole after acute Cholecystitis was ruled out and there were no other emergent/ urgent indications for an immediate, prior-to-obtaining-authorization operations, I have informed/warned patients, who wanted non-emergent or non-urgent operations, that businesses employing acute care surgeons do not make contracts with insurance companies to avoid extra work/expense for decreased reimbursement. That being said, for nonemergent operations, the patient will likely get an out-of-network bill and should call their insurance company if that would change their decision for wanting immediate (prior to discharge) surgery. | ||||||
5 | 8/12/2025 13:10:32 | Erika Wicks | As providers, we have no idea what coverage is or is not included for a patient. Our time is spent taking care of the patients' person, not their wallet. The administrative teams of the hospital and insurance companies should bear the responsibility for this. I have neither the intimate knowledge of multiple insurance benefits, nor the TIME to discuss this with patients. The burden of knowing what is covered is on the responsible consumer. Please do not make overworked, burned out medical providers who are leaving this industry in droves click one more box. | ||||||
6 | 8/12/2025 13:42:05 | STaci Bishop | While I think this is a benefit to the patients (and needed), there has to be some responsibility to the insurance companies as well-that they keep patients and providers notified of their in-network status (or not). Also, there needs to be mandated coverage if the patient has received emergency treatment at a facility that is out of network, to cover the transfer costs for the patient to go to an in-network facility. In essence, the insurance company can't say "we won't treat you at hospital A-but we also won't pay for transfer to hospital B (in network)". | ||||||
7 | 8/13/2025 14:19:47 | Sejal Quayle | I strongly oppose the institution of CME obligations for the Colorado state medical license. We already have multiple governing organizations which monitor the completion of CME activities. I believe that the entities that govern our board certifications are better equipped to understand whether the CME credits are appropriate for their own specialties. This will be simply more busy work for providers. | ||||||
8 | 10/1/2025 16:00:18 | Brittany Kunza | I’m not sure we know that about all of our patients in the visit in order to inform them. Sounds like something insurance companies should be actively educating people on. | ||||||
9 | 10/1/2025 16:03:59 | Karim A. Meijer, M.D. | The out of network versus in network conundrum is a healthcare policy problem that should not affect the physicians providing care. This problem has rolled downhill and is in the laps of doctors who are not to blame for this because they have no control. My car insurance company does not tell me what “network” of streets I can or can not drive on. Forcing doctors to be in-network by accepting unacceptable rates by insurance companies is not the answer. Public policy and hospital systems need to rectify this problem. | ||||||
10 | 10/1/2025 16:23:14 | Stephanie Wright | Out-of-network notification: Now that most EHR do eligibility checks prior to pt visits, it is easier to tell the pt when they are out of network. I would suspect most practices are utilizing this as they can then collect payment for the visit up front instead of potentially never getting paid for a higher than expected bill. Therefore, this is happening more and more as EHRs are improving this capability especially in the non-emergent outpt setting. I do not think a provision into state law is wise. Mostly because as good as any system is, there are some many insurance companies who have multitudes of plans and it is nearly impossible for an EHR to keep up with the nuances of every plan. Though it is not often, sometimes a plan will say the patient is eligible and then when we submit it to insurance is says that their particular plan was not in-network. As a whole we do a great job but the provider can not be responsible for ALL individuals and ALL plan, ALWAYS. There needs to be some responsibility on the patient to contact their plan when they are seeing a new provider and get confirmation that they are in-network. | ||||||
11 | 10/1/2025 18:57:05 | Karen Weese Bell | Dear Colorado Medical Board, I am a Colorado-licensed family physician with 15 years of clinical practice and dual board- certified by the American Board of Family Medicine and the College of Family Physicians of Canada. I have maintained CCFP certification for over a decade and was granted Fellowship status in 2022. I completed the MCCQE Parts I and II and have held the Licentiate of the Medical Council of Canada (LMCC) since 2010. I urge the Board to preserve full recognition of the LMCC as an equivalent pathway to U.S. examinations in the revised Rule 1.5. The LMCC is rigorous, internationally respected, and already authorized in Colorado’s current rules. Physicians like myself, holding dual board certifications and fellowship recognition, demonstrate that LMCC-based licensure produces safe, competent, and long-serving clinicians. I respectfully request the following of the revised rule: -State LMCC acceptance in unambiguous terms (“shall accept”), not discretionary language. -Protect current licensees and board-certified/fellowship-certified physicians from retroactive new burdens. -Maintain waiver flexibility for exam time limits. -Avoid redundant requirements that duplicate credentials without improving patient safety. -Provide clear, transparent criteria and appeal rights for equivalency determinations. Maintaining strong recognition of LMCC protects fairness for physicians and sustains access to high-quality care for Colorado patients. We are heading into a primary care crisis in this state and country. In order to best serve our Colorado patients, we need to ensure all qualified family physicians can continue to practice without interruption. Thank you, Karen Weese Bell, MD, ABFM, CCFP (F) | ||||||
12 | 10/1/2025 19:23:39 | Shirley Huang | I find as a healthcare consumer as well as physician and UM medical director, that these proposed changes and the form are very reasonable and much more transparent and helpful. | ||||||
13 | 10/1/2025 19:49:12 | Jim Shuler, DO, MS | Greetings, I'm writing specifically on the benzodiazepine issue. As an addiction medicine practitioner, I routinely provide care for those with benzodiazepine use disorder. It has been clear for many years that the standard of care is a slow taper (for long-term use) along the Ashton Manual guidelines and the new ASAM guidelines. Yet many SUD treatment facilities are detoxing people fairly quickly off of benzodiazepines against the mounting literature that abrupt (and that can mean over a month or two) cessation of benzodiazepines can have long-term downsides and may actually cause damage. The reason cited for this cessation as that many sober living facilities "don't support" benzodiazepine tapers. I'm hoping you'll take this into consideration with your modifications and I'm currently working with state legislators to get sober living facilities to support doing the right thing medically. In the meantime, the board's help with provider compliance will help things on our end. Thank you for your time in consideration of this. Jim | ||||||
14 | 10/2/2025 10:17:33 | Lauren | It is not the responsibility of providers to disclose coverage information to patients. Most of the time we are not aware of the coverage costs per patient. This is an undue burden for providers and increased liability on us. It is a responsibility of the insurance provider to inform the insured. I oppose this Rule 1000% | ||||||
15 | 10/2/2025 12:07:40 | Kristen Boyer | They should not be able to balance bill for out of network ER services/providers nor the services that come after stabilization. These ER groups purposely don’t have contracts with insurance companies so they get to bill out of network prices. Also you cannot control which ER you need to go to when there’s an emergency and you can not control if you need to get admitted to the hospital post stabilization so this should not be balance billed either. Balance billing should never be allowed unless the patient purposely chooses to go to an out of network provider electively and signs paperwork agreeing to pay out of network prices. If you choose an in network provider, it should not be allowed for any subsequent assistants or other providers that see you in connection to your elective procedure to balance bill either. | ||||||
16 | 10/4/2025 11:09:20 | Kevin Bauer | As an anesthesiologist, I don't have access to a persons medical coverage or insurance plan. In over 25 years of practice, I have never once looked at a patients insurance, medical coverage, or lack there of... We treat every person the same regardless of coverage status or ability to pay and just let the RCM department take care of the business side. I would have no mechanism to "inform" a patient about OON status. Plus, with the "surprise billing act" - It really does not matter and is a moot point since OON patients are billed at in network rates regardless. | ||||||
17 | 10/11/2025 13:13:50 | eugene master | As a practicing Colorado physician, I appreciate the Board’s efforts to improve transparency around out-of-network billing. In real care environments, patients sign documents while in pain, medicated, or overwhelmed. Procedural consent alone does not equal meaningful financial understanding. I feel the proposed changes still leave loopholes which work against the patients it is trying to protect, and patients remain vulnerable to unexpected financial liability despite nominal disclosure requirements. The document also doesn’t readily clarify notice for parents/guardians/caregivers when the patient is a child or other type of dependent (elder care, developmentally delayed adult, etc.) Parental/Caregiver distress is a real thing that can limit the person’s ability to understand or make rational decisions when their child/dependent is acutely ill. I recommend the targeted modifications to ensure patient protections are meaningful, not procedural. These changes would place the burden of proof more on the provider and less on the patient. • Standardize and regulate consent — Require use of a state-approved consent form (not provider-generated forms) to prevent confusing or coercive disclosures, with plain-language warnings. Consent should not be valid if obtained during treatment or within sedation/recovery windows, or if there is significant parental/caregiver/guardian distress. Patients must be offered an in-network alternative in writing before any waiver is considered informed. • Make website disclosure a condition of billing rights — If a provider’s required transparency page is not compliant or publicly registered with DORA, any balance billing attempt should be deemed invalid without requiring patient complaint. • Shift from permissive to prohibitive billing language — Replace “may balance bill if…” with “balance billing is prohibited except when…” to align regulatory intent with patient-centered care standards. • Tighten definition of “post-stabilization services” — Clarify that stabilization is reached only at discharge or formal transfer readiness to an equal or lower level of care, or to a higher level of care only if the transfer is not farther or would endanger their health, to prevent premature consent solicitation. For example, a patient with trauma is stabilized and requires transfer to an ICU. The nearest available ICU is out-of-network but is only 30 min away, while an “in-network” ICU is 2 hours away. If the patient is “stable for transfer” but still critically ill requiring intubation/ventilator, cardiac bypass, etc... a 2hr transfer is significantly riskier than a 30 min transfer to a higher level of care and the patient should not be financially punished for that. • Mandatory review, not discretionary enforcement — Replace “may result in discipline” with “shall initiate review for administrative action” to ensure compliance is enforced rather than selectively pursued. • Clarify that all services at in-network facilities are presumed protected from balance billing unless the provider proves otherwise, shifting burden away from the patient. Expand the definition of “ancillary” or create a default presumption that any unscheduled or incidental services automatically fall under no-balance-billing protection. • Replace "may result in discipline" with "shall trigger review for disciplinary action" to remove enforcement discretion that historically leads to under-enforcement. Require the Board to publish annual enforcement summaries to ensure accountability and transparency. • Add a consequence clause: Non-compliant disclosure automatically invalidates any attempt to collect a balance bill, making web transparency a condition precedent to legal billing. Require providers to register URL of disclosure page with the state for monitoring instead of relying on patient complaints. • Tighten definition of “stabilized” by stating that stability is considered achieved only when a patient is medically cleared for discharge or transfer to an equal or lower level of care, preventing premature triggering of consent opportunities. Require third-party (facility-level or insurance carrier) attestation before post-stabilization billing consent is considered valid. • Require guardian-specific financial disclosures — When the patient is a minor/dependent/etc., financial consent must explicitly state that parents/guardians are not obligated to accept out-of-network care and that refusal will not delay medically necessary treatment. • Prohibit implied coercion through “treatment delay language” — Consent forms and verbal communication must clearly state that refusal of out-of-network billing consent will not lead to reduced access or slower care for a child/dependent/etc. • Require delayed billing discussion where clinically appropriate — For pediatric emergencies, financial consent discussions should be deferred until after medical stabilization and parental emotional readiness, except where immediate elective choices are involved. Thank you for considering these refinements and for continuing to work towards supporting Colorado patients and their families! Eugene Master, DO Pediatrician and Instructor of Pediatric Medicine University of Colorado School of Medicine Children’s Hospital of Colorado | ||||||
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