Tuesday, January 01, 2008

Dear PHC, Please vote yes on mini clinics

Way back in May, I wrote in support of storefront clinics of the type proposed at that time by the company that owns CVS pharmacies. Since then, there has been a lot of back-and-forth on the issue. Significantly, the state Department of Public Health looked into the issue and received lots of comments as to how best to proceed.

After considering all these comments, the DPH has proposed regulations on the issue, and now it is up to the state's Public Health Council to rule on the matter. Please take a look at them, especially the last two pages, which address the programmatic requirements of this new model of clinic. These rules would be applicable to anybody who wanted to start a limited service clinic -- whether a company like CVS, a community health center, or even a hospital.

While I am further along the spectrum on this issue, I think that the DPH staff did an admirable job in coming up with a series of rules and regulations that would make these clinics a valuable and convenient adjunct to other parts of the health care delivery system. The rules permit innovation while protecting the public. They introduce the potential for some competition while reinforcing connections to primary care doctors.

In short, this state agency did what we would hope a public agency would do. It carefully considered a variety of points of view and crafted a set of regulations that broadly protect the public interest. I hope that the members of the Public Health Council will approve the regulations at its meeting on January 9. Were they to turn them down, I fear that they would send a clear signal that Massachusetts is not a friendly place for new health care delivery concepts that offer convenience to the public and the potential to alleviate crowding of Emergency Rooms and other higher acuity sites of care.


Anonymous said...

After reading the last few pages of the proposed rules, it looks to me like regulators in Massachusetts simply don't trust markets and don't believe individuals are capable of acting in their own best interest. Doctors, for their part, look to be trying to stifle competition which is consistent with their decades long history.

It's not as though retail clinics are a brand new concept that has not been tried anywhere else. They have been around elsewhere in the country since 2000, and there are now an estimated 700 of them operating nationwide. Is their any evidence whatsoever that more people are dying or winding up in ER's gravely ill because they sought care from an NP at a retail clinic instead of from an MD? Besides, it's not as though MD's always get the diagnosis right. I, for one, would be more than willing to seek care at a retail clinic for a minor medical problem even if I could get an appointment with my PCP on a timely basis. I don't think I need an MD to tell me whether or not I have strep throat or to administer a flu shot. I think the clinics have lots of potential to take some of the pressure off of overcrowded ER's. They are also well ahead of the rest of the healthcare industry on price transparency and electronic records. The large companies behind many of these clinics like CVS, Walgreen, Wal-Mart, Target, etc. have a reputation to protect. They are not going to do anything stupid. We should be cheering them on, not trying to stand in their way. The doctors, who see them as competition, have a different view, of course.

Anonymous said...


I read that hospitals are trying their own retail clinics to unburden their ER's, and having their own docs supervise the clinics (for pay, of course). This is said to provide better continuity of care between the clinics and the inpatient side in terms of IT, records, etc. What do you think of this idea?

Anonymous said...

As noted in my earlier post, I agree with you, Barry, on many of those points . . . but I am pleased to see some progress.

Anonymous said...


I have heard of the same, but don't recall where those were located. Do you know? And do you know how well they have worked?

e-Patient Dave said...

To recap what I said last May, having experienced a walk-in clinic in 2006 (Minute Clinic, in Minnesota), it's a complete no-brainer to me. The service was fast, convenient, inexpensive and effective - and since it was in my supermarket, it was within a mile of my house.

You mention "These rules would be applicable to anybody who wanted to start a limited service clinic ... even a hospital." Mayo's apparently doing it - recently I happened across Major players catch a case of quick-clinic fever, about how they're trying a walk-in model. "Once derided by doctors as providing disjointed and possibly unsafe care, medical centers are starting to open their own retail clinics as a way to keep existing patients and reach new ones." Huzzah.

But what's up with the statement on page 5 of the proposed regulations, "'clinic' shall NOT include a clinic conducted by a hospital licensed under M.G.L. c. 111, §51 or by the federal government, or the commonwealth"? (capitalization added)

e-Patient Dave said...

Reading the last two pages of the proposed regulations, I find myself wondering what's in corresponding regulations in other states.

What's up with (F), saying clinics must develop policies to prevent repeat encounters with individual patients?? What on earth is that about? If I like the service, I'm not supposed to keep using it??

Perhaps they meant something much more specific, e.g. preventing repeat visits for a condition that isn't responding to the clinic's treatments. (A curmudgeon might say that the same policy should be enforced for regular MDs and hospitals too, but I'm not that curmudgeon.) Seriously, I wonder what they really mean.

Paragraph (H) says clinic personnel must not promote services in the same retail location. "Promote" needs clarification. In my case there was a pharmacy in the same supermarket, and any regulation should allow mentioning its existence, e.g. "There's a pharmacy over there, or you can go to any other one you want," as in (I)(3). Perhaps they could word it something like "clinic personnel do not promote the use of services provided by the host retail location, in preference to other alternatives."

But in the larger picture those are details to be ironed out thoughtfully. I too am pleased to see what seems to be a substantial step in the right direction.

Anonymous said...

I remember reading that the Mayo Clinic had one, but forgot where I read it. Here, however, is a link obtained off a google search:


This could be an interesting development, but I'm a little confused as to how much overlap these will have with urgent care clinics. I know in my major metropolitan area, some hospitals own several urgent care clinics. Seems like a hospital would be better off to own an urgent care place and provide minute clinic type services there - one could see more types of patients and reap the same relationship/IT benefits.

Anonymous said...


On an unrelated subject but knowing your interest in quality assurance and transparency, I'd like to call your attention to Maggie Mahar's post on The Health Care Blog regarding the use of health care process checklists - and her comment to her own post citing an op-ed article in the New York Times revealing that the use of checklists to improve central line infection rates was forbidden by a government agency. My mind is utterly blown. Perhaps you would like to post about this on your blog; the original sources are posted by eliotg in the comment section. Sorry to use this forum but I forgot your email address.

Mike, MPA, CEN, CCRN said...

As some of you have mentioned this is not a new concept by any means these "doc in the boxes" as I affectionately call them have been around for some time. The military health care system uses them quite a bit within their health care organizational structure to help cover service areas. Where I work at Cape Cod Health Care (CCHC) we have a number of clinics in the community that are part of CCHC that provide services to the Cape. I am surprised that more organizations don't have their own satellite clinics. This works.

Anonymous said...

Some doctors have NPs in their offices and you even get them as your "primary." But if they set up their own shop...ooo, the docs freak.