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April 13, 2020
The Honorable Nancy Pelosi
Speaker of the House
United States House of Representatives
H-222, US Capitol
Washington, DC 20515
The Honorable Kevin McCarthy
Minority Leader
United States House of Representatives
H-204, US Capitol
Washington, DC 20515
The Honorable Mitch McConnell
Senate Majority Leader
United States Senate
S-230, US Capitol
Washington, DC 20510
The Honorable Charles E. Schumer
Senate Minority Leader
United States Senate
S-221, US Capitol
Washington, DC 20510
Dear Speaker Pelosi, Leader McConnell, Leader McCarthy, and
Leader Schumer,
On behalf of the undersigned organizations, we are writing
today to thank you for your
leadership in response to the ongoing COVID-19 pandemic. We
know that these are difficult
times for so many, and we appreciate the bipartisan efforts by
Congress to help healthcare
providers, facilities and small businesses in these trying times.
While we recognize that Congress
has taken important steps to help mitigate this crisis, COVID-19
continues to spread and there is
need for more protections and relief efforts to help our
healthcare workforce.
As member organizations of the Patients Access to Responsible
Care Alliance (PARCA), we
represent non-MD/DO Medicare recognized healthcare
providers who provide high-quality,
evidence-based care to millions of Americans, especially to
those living in rural and underserved
areas. As the provider of choice for many patients, our members
are serving countless essential
and nonessential but critical healthcare roles during the
pandemic. Many of the providers that we
represent are working to the full extent of their clinical training
during this crisis, stepping in to
mitigate provider shortages by providing care that is within
their scope but outside of their
primary day to day responsibilities prior to the outbreak.
As you look to prepare the next relief package, we hope that
you’ll keep these concerns in mind:
Hazard Pay for Healthcare Workers
All of the providers that we represent are working in situations
where there is an increased risk
of infection from COVID-19, often exacerbated by the lack of
Personal Protective Equipment
(PPE). Some are on the front lines performing intubations and
treating COVID patients, while
others are working day and night outside of the ICU to ensure
that patients have access to the
important and ongoing care that they need.
2
We think that it’s important, as Congress considers hazard pay
measures to support our
healthcare workforce, that these measures be inclusive of all
types of healthcare providers. We
stand united in our support for hazard pay that includes all
providers, in all settings, as no one
who works in the healthcare space is immune from the
heightened threat of COVID infection.
Data has shown that healthcare and mental health workers are
particularly susceptible to
COVID-191. As our providers work to continue care to as many
people as they can, they are
being asked to work longer hours, with greater exposure and a
lack of available testing and PPE.
We need to make sure that all healthcare providers are included
in any hazard pay relief efforts
and urge you to ensure that any package contains inclusive
language.
Ensuring Access to Personal Protective Equipment, Testing, and
Provider Safety
Unfortunately, we continue to see a lack of Personal Protective
Equipment available for
providers, especially providers who are continuing to interact
with patients outside of the ICU
setting. With continued concerns about the National Strategic
Stockpile, states and facilities still
struggling with limited resources, and a backlog in the
production of new PPE, we are calling on
Congress and the Administration to use their full powers to
secure additional PPE through all
available avenues.
We believe it’s important that the authorization within the
Defense Production Act be utilized to
its utmost extent to produce critical PPE and ventilators. With
many locations expecting to reach
peak COVID caseloads in the coming weeks and the possibility
that other locations, especially
rural locations, could peak later, it’s critical that we open the
pipeline for PPE production as fast
as possible.
It’s also important to ramp up production of PPE to ensure that
all providers have access to
needed protection. While we understand the need and urgency
of getting PPE to the frontlines in
hospitals and ICUs, this is leaving a dangerous gap in PPE for
other providers. Many providers
are caring for patients who have urgent and critical healthcare
needs outside of the pandemic, but
who are unable to access necessary PPE. The lack of PPE for
these providers, coupled with the
continued backlog and lack of readily available COVID-19
testing, creates a dangerous
environment where healthcare providers may be unwittingly
exposing themselves to infection
while providing care to patients.
The lack of testing for healthcare workers is particularly
concerning, leaving many providers
interacting with patients who may infected but may not be
symptomatic and unable to be tested.
This lack of testing has the potential to increase transmission
among both healthcare and mental
1 https://www.washingtonpost.com/health/health-care-workers-
worry-about-coronavirus-
protection/2020/03/05/be04d5a8-5e33-11ea-9055-
5fa12981bbbf_story.html
3
health providers and their patients, opening up unnecessary
risks to everyone at a time when the
healthcare system is already stretched thin.
Additionally, it’s important that healthcare providers who feel
unsafe in their work environment
have the ability to protect their own health. Providers who may
be immunocompromised in a
way that would normally not affect their job, may be at a highly
increased risk due to COVID-
19. It’s paramount that as we watch so many healthcare
providers step up to take on the
challenge of COVID-19, that we provide more robust
protections for those providers for whom
this is an unsafe and potentially life-threatening situation. We
call on Congress to enact further
protections for these healthcare workers, by requiring the
Occupational Safety and Health
Administration to create more vigorous protections for
healthcare workers, including those for
whom going to work may be unsafe, through emergency
temporary standards to protect workers
from the potential COVID-19 pandemic.
Aid for Unemployed and Underemployed Healthcare Providers
While the CARES Act provided significant relief for small
businesses and independent
contractors, we are still seeing many healthcare providers and
practices fall through the cracks.
With the reduction and cancelation of elective procedures, many
providers are now unemployed
or underemployed. Compounding this issue, we have seen
healthcare providers and other small
businesses struggling to navigate the Paycheck Protection
Program loan process, or be turned
away by lenders, leaving them stranded and helpless. We cannot
ask our healthcare providers to
risk their lives caring for patients in their time of need, only to
be abandoned when they’re
struggling.
We are asking Congress to create a grant program that would
specifically help healthcare
providers remain whole during these tough times. We know that
so many of our nation’s
healthcare providers who are currently sidelined or facing
significant reductions in their work
and pay will become urgently needed again, should their
communities face a COVID outbreak,
or when facilities return to performing elective procedures
faced with a major backlog. We hope
that Congress will consider grants to healthcare providers and
practices similar to what has been
proposed by Senators Bennet and Barrasso in S. 3559/H.R.
6365, a bill with broad bipartisan
support. We also encourage Congress to increase the cap on
salaries that these grants can cover,
as the proposed grants are below the level set in the Paycheck
Protection Program. We think
allowing healthcare providers to receive a certain percentage of
their salary at the time of
disruption would provide much needed relief.
Lenders are overwhelmed with a number of applications for
assistance in these tough economic
times. We are encouraged to see Congress considering
increasing funds for the loan programs
and lifting caps on what these institutions may lend, but there is
an urgent need to provide relief
specifically for our healthcare workforce now, through a grant
program.
4
Support for Rural Facilities
While the money provided through the CARES Act for hospitals
was an important step towards
ensuring that hospitals can remain open and solvent, it has
created fierce competition among
hospitals, with rural and critical access hospitals forced to
compete with larger urban hospitals
who typically have more resources. With this in mind, we are
calling for a direct grant and loan
program to help these smaller rural and critical access facilities.
These rural hospitals were already facing critical shortfalls and
financial distress even before the
current pandemic. A recent study by the Chartis Center of Rural
Health showed that 120 rural
hospitals have closed in the last decade and the rate of closures
continues to increase.2 The
problem is getting worse, with one out of every four rural
facilities at risk for closure.3
Unfortunately, the COVID-19 pandemic will only exacerbate
this problem, as rural and critical
access facilities face the double hit of being forced to cancel
elective procedures which provide
revenue, and the potential that COVID-19 cases could start to
rise in the coming weeks, just as
these facilities are in dire economic straits4.
The providers we represent tend to predominate in these
facilities, which serve populations that
tend to be older and more susceptible to the COVID-19 virus.
With their resources already
spread thin, a surge of COVID cases could prove disastrous to
many of these facilities. We have
also witnessed the reallocation of resources from these facilities
to help urban facilities that are
overwhelmed, such as in New York state, which in turns leaves
these facilities even more
vulnerable to a potential future spike. We must make sure that
these facilities have the resources
they need to stay open, to prepare for a surge in COVID-19
cases, and to avoid detrimental
layoffs of staff, so that they can continue to serve our most
vulnerable populations.
Increased Access to Telehealth Services
Finally, there is a need to continue to increase access to
telehealth services. As healthcare and
mental health providers work to continue to provide care for our
patients in the safest way
possible, it’s clear that removing barriers to telehealth practice
and ensuring that all providers are
able to treat patients and be properly reimbursed for those
services is crucial.
Many of the providers that we represent offer important
healthcare and mental health services
that can be delivered by telehealth. Telehealth should be
implemented to the full extent and made
as flexible as possible. Unnecessary barriers in the delivery of
telehealth should be removed and
telehealth access should be expanded by establishing coverage
of audio-only services. Millions
2 https://www.ivantageindex.com/wp-
content/uploads/2020/02/CCRH_Vulnerability-
Research_FiNAL-
02.14.20.pdf
3 https://www.forbes.com/sites/claryestes/2020/02/24/1-4-rural-
hospitals-are-at-risk-of-closure-and-the-
problem-is-getting-worse/#4abd2b3d1bc0
4 https://thehill.com/homenews/state-watch/491032-rural-
america-braces-for-coronavirus
5
of Americans do not have the reliable broadband access needed
to support full audio-visual
telecommunications. Expanding access to telehealth will help
minimize the disruption to the
healthcare system, allowing some patients to continue to access
healthcare in a safe manner
during the pandemic. We support including the Creating
Opportunities Now for Necessary and
Effective Care Technologies Act or CONNECT for Health Act
(S.2741/H.R.4932), in the next
COVID relief package. Additionally, Congress should continue
to encourage the Administration
to use the authority granted to it under section 3703 of the
Coronavirus Aide, Relief, and
Economic Security Act to make as many healthcare providers
eligible to provide telehealth
services as possible.
As a coalition, PARCA wants to make sure that any relief
efforts are inclusive of all provider
types. It’s important that we care for all our providers during
this emergency to ensure that we
are able to provide the highest level and the widest breadth of
care to those in need. The
suggestions that we have made are necessary for the healthcare
industry, to keep providers
protected, safe and able to care for patients.
We hope that you and your colleagues will consider these ideas
as you work on developing the
next package of COVID relief. As always, the PARCA coalition
and our members organizations
stand ready to be a resource to Congress and the Administration
as you continue these important
updates. Please don’t hesitate to reach out to PARCA Chair Ben
Wallner at [email protected]
or to any of our member organizations if we can be helpful.
Signed,
American Academy of Audiology
American Academy of PAs
American Association of Nurse Anesthetists
American Association of Nurse Practitioners
American Chiropractic Association
American College of Nurse-Midwives
American Nurses Association
American Occupational Therapy Association
American Physical Therapy Association
American Psychological Association
American Podiatric Medical Association
American Speech-Language-Hearing Association
National Association of Pediatric Nurse Practitioners
National Association of Social Workers
National League for Nursing

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1 April 13, 2020 The Honorable Nancy Pelosi Spea

  • 1. 1 April 13, 2020 The Honorable Nancy Pelosi Speaker of the House United States House of Representatives H-222, US Capitol Washington, DC 20515 The Honorable Kevin McCarthy Minority Leader United States House of Representatives H-204, US Capitol Washington, DC 20515 The Honorable Mitch McConnell Senate Majority Leader United States Senate S-230, US Capitol Washington, DC 20510 The Honorable Charles E. Schumer Senate Minority Leader United States Senate S-221, US Capitol Washington, DC 20510
  • 2. Dear Speaker Pelosi, Leader McConnell, Leader McCarthy, and Leader Schumer, On behalf of the undersigned organizations, we are writing today to thank you for your leadership in response to the ongoing COVID-19 pandemic. We know that these are difficult times for so many, and we appreciate the bipartisan efforts by Congress to help healthcare providers, facilities and small businesses in these trying times. While we recognize that Congress has taken important steps to help mitigate this crisis, COVID-19 continues to spread and there is need for more protections and relief efforts to help our healthcare workforce. As member organizations of the Patients Access to Responsible Care Alliance (PARCA), we represent non-MD/DO Medicare recognized healthcare providers who provide high-quality, evidence-based care to millions of Americans, especially to those living in rural and underserved areas. As the provider of choice for many patients, our members are serving countless essential and nonessential but critical healthcare roles during the pandemic. Many of the providers that we represent are working to the full extent of their clinical training during this crisis, stepping in to mitigate provider shortages by providing care that is within their scope but outside of their primary day to day responsibilities prior to the outbreak. As you look to prepare the next relief package, we hope that you’ll keep these concerns in mind:
  • 3. Hazard Pay for Healthcare Workers All of the providers that we represent are working in situations where there is an increased risk of infection from COVID-19, often exacerbated by the lack of Personal Protective Equipment (PPE). Some are on the front lines performing intubations and treating COVID patients, while others are working day and night outside of the ICU to ensure that patients have access to the important and ongoing care that they need. 2 We think that it’s important, as Congress considers hazard pay measures to support our healthcare workforce, that these measures be inclusive of all types of healthcare providers. We stand united in our support for hazard pay that includes all providers, in all settings, as no one who works in the healthcare space is immune from the heightened threat of COVID infection. Data has shown that healthcare and mental health workers are particularly susceptible to COVID-191. As our providers work to continue care to as many people as they can, they are being asked to work longer hours, with greater exposure and a lack of available testing and PPE. We need to make sure that all healthcare providers are included
  • 4. in any hazard pay relief efforts and urge you to ensure that any package contains inclusive language. Ensuring Access to Personal Protective Equipment, Testing, and Provider Safety Unfortunately, we continue to see a lack of Personal Protective Equipment available for providers, especially providers who are continuing to interact with patients outside of the ICU setting. With continued concerns about the National Strategic Stockpile, states and facilities still struggling with limited resources, and a backlog in the production of new PPE, we are calling on Congress and the Administration to use their full powers to secure additional PPE through all available avenues. We believe it’s important that the authorization within the Defense Production Act be utilized to its utmost extent to produce critical PPE and ventilators. With many locations expecting to reach peak COVID caseloads in the coming weeks and the possibility that other locations, especially rural locations, could peak later, it’s critical that we open the pipeline for PPE production as fast as possible. It’s also important to ramp up production of PPE to ensure that all providers have access to needed protection. While we understand the need and urgency
  • 5. of getting PPE to the frontlines in hospitals and ICUs, this is leaving a dangerous gap in PPE for other providers. Many providers are caring for patients who have urgent and critical healthcare needs outside of the pandemic, but who are unable to access necessary PPE. The lack of PPE for these providers, coupled with the continued backlog and lack of readily available COVID-19 testing, creates a dangerous environment where healthcare providers may be unwittingly exposing themselves to infection while providing care to patients. The lack of testing for healthcare workers is particularly concerning, leaving many providers interacting with patients who may infected but may not be symptomatic and unable to be tested. This lack of testing has the potential to increase transmission among both healthcare and mental 1 https://www.washingtonpost.com/health/health-care-workers- worry-about-coronavirus- protection/2020/03/05/be04d5a8-5e33-11ea-9055- 5fa12981bbbf_story.html 3 health providers and their patients, opening up unnecessary risks to everyone at a time when the healthcare system is already stretched thin.
  • 6. Additionally, it’s important that healthcare providers who feel unsafe in their work environment have the ability to protect their own health. Providers who may be immunocompromised in a way that would normally not affect their job, may be at a highly increased risk due to COVID- 19. It’s paramount that as we watch so many healthcare providers step up to take on the challenge of COVID-19, that we provide more robust protections for those providers for whom this is an unsafe and potentially life-threatening situation. We call on Congress to enact further protections for these healthcare workers, by requiring the Occupational Safety and Health Administration to create more vigorous protections for healthcare workers, including those for whom going to work may be unsafe, through emergency temporary standards to protect workers from the potential COVID-19 pandemic. Aid for Unemployed and Underemployed Healthcare Providers While the CARES Act provided significant relief for small businesses and independent contractors, we are still seeing many healthcare providers and practices fall through the cracks. With the reduction and cancelation of elective procedures, many providers are now unemployed or underemployed. Compounding this issue, we have seen healthcare providers and other small businesses struggling to navigate the Paycheck Protection Program loan process, or be turned away by lenders, leaving them stranded and helpless. We cannot ask our healthcare providers to
  • 7. risk their lives caring for patients in their time of need, only to be abandoned when they’re struggling. We are asking Congress to create a grant program that would specifically help healthcare providers remain whole during these tough times. We know that so many of our nation’s healthcare providers who are currently sidelined or facing significant reductions in their work and pay will become urgently needed again, should their communities face a COVID outbreak, or when facilities return to performing elective procedures faced with a major backlog. We hope that Congress will consider grants to healthcare providers and practices similar to what has been proposed by Senators Bennet and Barrasso in S. 3559/H.R. 6365, a bill with broad bipartisan support. We also encourage Congress to increase the cap on salaries that these grants can cover, as the proposed grants are below the level set in the Paycheck Protection Program. We think allowing healthcare providers to receive a certain percentage of their salary at the time of disruption would provide much needed relief. Lenders are overwhelmed with a number of applications for assistance in these tough economic times. We are encouraged to see Congress considering increasing funds for the loan programs and lifting caps on what these institutions may lend, but there is an urgent need to provide relief specifically for our healthcare workforce now, through a grant program.
  • 8. 4 Support for Rural Facilities While the money provided through the CARES Act for hospitals was an important step towards ensuring that hospitals can remain open and solvent, it has created fierce competition among hospitals, with rural and critical access hospitals forced to compete with larger urban hospitals who typically have more resources. With this in mind, we are calling for a direct grant and loan program to help these smaller rural and critical access facilities. These rural hospitals were already facing critical shortfalls and financial distress even before the current pandemic. A recent study by the Chartis Center of Rural Health showed that 120 rural hospitals have closed in the last decade and the rate of closures continues to increase.2 The problem is getting worse, with one out of every four rural facilities at risk for closure.3 Unfortunately, the COVID-19 pandemic will only exacerbate this problem, as rural and critical access facilities face the double hit of being forced to cancel elective procedures which provide revenue, and the potential that COVID-19 cases could start to rise in the coming weeks, just as these facilities are in dire economic straits4.
  • 9. The providers we represent tend to predominate in these facilities, which serve populations that tend to be older and more susceptible to the COVID-19 virus. With their resources already spread thin, a surge of COVID cases could prove disastrous to many of these facilities. We have also witnessed the reallocation of resources from these facilities to help urban facilities that are overwhelmed, such as in New York state, which in turns leaves these facilities even more vulnerable to a potential future spike. We must make sure that these facilities have the resources they need to stay open, to prepare for a surge in COVID-19 cases, and to avoid detrimental layoffs of staff, so that they can continue to serve our most vulnerable populations. Increased Access to Telehealth Services Finally, there is a need to continue to increase access to telehealth services. As healthcare and mental health providers work to continue to provide care for our patients in the safest way possible, it’s clear that removing barriers to telehealth practice and ensuring that all providers are able to treat patients and be properly reimbursed for those services is crucial. Many of the providers that we represent offer important healthcare and mental health services that can be delivered by telehealth. Telehealth should be implemented to the full extent and made as flexible as possible. Unnecessary barriers in the delivery of
  • 10. telehealth should be removed and telehealth access should be expanded by establishing coverage of audio-only services. Millions 2 https://www.ivantageindex.com/wp- content/uploads/2020/02/CCRH_Vulnerability- Research_FiNAL- 02.14.20.pdf 3 https://www.forbes.com/sites/claryestes/2020/02/24/1-4-rural- hospitals-are-at-risk-of-closure-and-the- problem-is-getting-worse/#4abd2b3d1bc0 4 https://thehill.com/homenews/state-watch/491032-rural- america-braces-for-coronavirus 5 of Americans do not have the reliable broadband access needed to support full audio-visual telecommunications. Expanding access to telehealth will help minimize the disruption to the healthcare system, allowing some patients to continue to access healthcare in a safe manner during the pandemic. We support including the Creating Opportunities Now for Necessary and Effective Care Technologies Act or CONNECT for Health Act (S.2741/H.R.4932), in the next COVID relief package. Additionally, Congress should continue to encourage the Administration to use the authority granted to it under section 3703 of the Coronavirus Aide, Relief, and Economic Security Act to make as many healthcare providers eligible to provide telehealth services as possible.
  • 11. As a coalition, PARCA wants to make sure that any relief efforts are inclusive of all provider types. It’s important that we care for all our providers during this emergency to ensure that we are able to provide the highest level and the widest breadth of care to those in need. The suggestions that we have made are necessary for the healthcare industry, to keep providers protected, safe and able to care for patients. We hope that you and your colleagues will consider these ideas as you work on developing the next package of COVID relief. As always, the PARCA coalition and our members organizations stand ready to be a resource to Congress and the Administration as you continue these important updates. Please don’t hesitate to reach out to PARCA Chair Ben Wallner at [email protected] or to any of our member organizations if we can be helpful. Signed, American Academy of Audiology American Academy of PAs American Association of Nurse Anesthetists American Association of Nurse Practitioners American Chiropractic Association American College of Nurse-Midwives American Nurses Association American Occupational Therapy Association American Physical Therapy Association
  • 12. American Psychological Association American Podiatric Medical Association American Speech-Language-Hearing Association National Association of Pediatric Nurse Practitioners National Association of Social Workers National League for Nursing