Protecting small business WC premiums

Below is the text of my presentation to the South Carolina Workers’ Compensation Commission public hearing today.

We appreciate the opportunity to be heard on the issue of  “Maximum Allowable Payments to Medical Practitioners”. 
The South Carolina Small Business Chamber of Commerce is a 5000 plus member advocacy organization.  We have a long history of promoting an effective and efficient Workers’ Compensation System that helps our injured workers receive the proper and timely health care and benefits they need to return to their jobs as productive workers. 
As champions of this needed process we have also been staunch guardians of legislative, judicial and Commission decisions that would unjustifiably increase costs and thus business premiums.
Today we are here to oppose the proposal to amend Regulation 67-1302(A), which requires the Commission to use a relative value scale and a single conversion factor when establishing maximum allowable payments for medical services provided by medical practitioners.
We support a fee schedule that is based on an objective, scientifically-based analysis of medical costs such as Medicare’s Resource-Based Value Scale (RBRVS) that the Commission presently uses. 
Proposing to eliminate the use of the RBRVS and single conversion factor without proposing a comparable national data-driven replacement process is a recipe for an all-out assault on the limited-resourced Commission by well-financed special interests seeking to increase their compensation.
The end result of amending the Regulation as proposed will be much higher workers’ compensation insurance premiums for South Carolina businesses with no improvement in healthcare outcomes for our injured workers and their employers. 
The Commission has invested much time in making sure that the present medical services compensation system is fair to all parties—businesses, providers and workers.  Amending the Regulation and allowing multiple conversion factors will undermine this delicate balance and drive up system costs at a time when workers’ compensation loss costs, and thus premiums, are in decline.
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