Vermont Guide to Health Care Law

        

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Health Care Professional –
Patient Relationship


Topics Covered on This Page

Initiation & Termination Of The Patient-Physician Relationship
Duty to warn
Residents’ Rights (Long-Term Care Setting)
Patients’ Rights (Hospital Setting)
Reporting to DMV
Professional Courtesy

About the Author & Editor

 

By Jessa Barnard

Vermont Medical Society

Chapter Editor:
Madeleine Mongan, Esq.
Vermont Medical Society

 

Initiation and Termination of the Patient-Physician Relationship


What constitutes the beginning of a patient-physician relationship?
Vermont law does not specify what constitutes the beginning of a patient-physician relationship. The CPT Manual defines a new patient as a patient who has not received any professional services from the physician or another physician of the same specialty who belongs to the same group practice within the past three years. Professional services are defined as face-to-face services provided by a physician and reported by a specific CPT code.

As a general precaution, a physician should consider that the relationship has begun at any point where the physician or a member of the physician’s practice has offered to provide a medical service, unless it has been explicitly stated in writing to the patient that the physician is providing care only on an interim or emergency basis and that the patient should continue looking for another physician. If, after offering to provide services to a patient, the physician decides that he or she does not want to or is unable to serve that patient, the physician should follow the process for discharging a patient as described below.

May physicians refuse to see a specific patient even if the practice is accepting other new patients?
Yes, according to AMA ethical opinion 10.05, physicians have the prerogative to choose whether to enter into a patient-physician relationship with any individual. However, a physician must always respond in cases of emergency and cannot discriminate based on race, creed, color, national origin, marital status, sex or sexual orientation. The physician should also be aware of any contractual relationship, for example a participation agreement with an insurer that requires him or her to treat certain patients.

As a general guideline, the physician should balance a prospective new patient’s medical need with the needs of the physician’s other patients. According to the AMA’s opinion, “greater medical necessity of a service engenders a greater obligation to treat.” Other reasons to refuse treatment are if:

  • the treatment request is beyond the physician’s competence;
  • the treatment request is scientifically or medically invalid; or
  • the treatment request is incompatible with the physician’s personal, religious, or moral beliefs.

For more information, go to:
http://www.ama-assn.org/apps/pf_new/pf_online?f_n=browse&doc=policyfiles/HnE/E-10.05.HTM&&s_t=&st_p=&nth=1&prev_pol=policyfiles/HnE/E-9.132.HTM&nxt_pol=policyfiles/HnE/E-10.01.HTM&

May physicians discharge patients from their care?
Yes, physicians are allowed to end the physician-patient relationship if it is the best option. Such situations may include a patient who is consistently noncompliant, unreasonably demanding, or threatening to you or your staff. It may also be necessary to transition a patient due to the relocation or retirement of a health care professional.

Are there guidelines to follow when discharging a patient from the care of a practice?
The Vermont Board of Medical Practice (VBMP) and the American Medical Association (AMA) offer guidance on the process physicians should follow when discharging a patient from their practice.

The VBMP policy states that the board recognizes that the physician-patient relationship may be terminated by either party. However, termination must be done in compliance with the physician’s obligation to support continuity of care for the patient. The policy requires that written notice of termination be “presented to the patient by a method to ensure that the patient received the notice.” Records should be transferred promptly to the new clinician regardless of whether the patient has an outstanding bill. The physician should continue to provide treatment for existing problems or emergencies for at least a thirty-day transition period. 

For more information, go to:
http://healthvermont.gov/hc/med_board/010699terminationadvisory.pdf

AMA policy 8.11, Neglect of Patient, states that while physicians “are free to choose whom they will serve,” once they have accepted a case, they “should not neglect the patient.” AMA Policy 8.115, Termination of the Physician-Patient Relationship, elaborates: “Physicians have an obligation to support continuity of care for their patients. While physicians have the option of withdrawing from a case, they cannot do so without giving notice to the patient, the relatives, or responsible friends sufficiently long in advance of withdrawal to permit another medical attendant to be secured.”

For more information, go to:
http://www.ama-assn.org/apps/pf_new/pf_online?f_n=browse&doc=policyfiles/HnE/E-8.11.HTM&&s_t=&st_p=&nth=1&prev_pol=policyfiles/HnE/E-7.05.HTM&nxt_pol=policyfiles/HnE/E-8.01.HTM&

http://www.ama-assn.org/apps/pf_new/pf_online?f_n=browse&doc=policyfiles/E-8.00.HTM&&s_t=&st_p=&nth=1&prev_pol=policyfiles/HnE/H-525.998.HTM&nxt_pol=policyfiles/E-1.00.HTM&

http://www.ama-assn.org/apps/pf_new/pf_online?f_n=browse&doc=policyfiles/HnE/E-8.115.HTM&&s_t=&st_p=&nth=1&prev_pol=policyfiles/HnE/E-7.05.HTM&nxt_pol=policyfiles/HnE/E-8.01.HTM&

What constitutes abandonment of a patient? How can I avoid charges of neglect or abandonment?
The AMA Office of General Counsel states that “[a]bandonment is defined as the termination of a professional relationship between physician and patient at an unreasonable time and without giving the patient the chance to find an equally qualified replacement.”

For more information, go to
http://www.ama-assn.org/ama/pub/category/4609.html

AMA Opinion E-10.01, Fundamental Elements of the Patient-Physician Relationship elaborates:  

The patient has the right to continuity of health care. The physician has an obligation to cooperate in the coordination of medically indicated care with other health care providers treating the patient. The physician may not discontinue treatment of a patient as long as further treatment is medically indicated, without giving the patient reasonable assistance and sufficient opportunity to make alternative arrangements for care.

A 1999 Vermont Board of Medical Practice advisory similarly emphasizes continuity of care. According to the advisory, “abandoning” a patient is considered unprofessional conduct under Vermont law. In assessing whether a physician has abandoned a patient, the Board will consider three factors:

  • Whether the physician gave the patient at least 30 days notice (in writing) if ending a treatment relationship. The physician does not have to state a reason for ending the relationship, only his or her belief that it is best to do so;

  • Whether the physician provided necessary ongoing or emergency treatment for at least 30 days while a patient transitions to a new physician; and

  • Whether the physician transferred records to a new physician promptly, as chosen by the patient, regardless of whether the patient had any outstanding bills with the practice.

The AMA also suggests that a physician provide resources and/or recommendations to help a patient locate another physician of appropriate specialty.

For more information, go to:
http://healthvermont.gov/hc/med_board/010699terminationadvisory.pdf

http://www.ama-assn.org/apps/pf_new/pf_online?f_n=browse&doc=policyfiles/HnE/E-10.01.HTM&&s_t=&st_p=&nth=1&prev_pol=policyfiles/HnE/E-9.132.HTM&nxt_pol=policyfiles/HnE/E-10.01.HTM&

What could the penalties be?
A patient who believes that he or she has been abandoned can file a complaint with the Board of Medical Practice charging the physician with unprofessional conduct. The Board has the authority to issue warnings, impose fines, or condition, suspend or revoke licenses to practice medicine.

In addition, if a physician violates the AMA Code of Ethics, the AMA and the Vermont Medical Society can consider terminating membership.

In sum, you may terminate the physician-patient relationship if it becomes necessary, but you cannot neglect or abandon a patient and must transfer the patient’s medical records to the new physician. To avoid allegations of neglect or abandonment, you should provide ample notification and assistance during the transition.

Sources/Resources:

What immediate and longer-term steps can a practice take when a patient is dangerous, threatening or inappropriate for the practice?
If a patient is dangerous or threatening to staff or other patients you can ask him or her to leave your office immediately, and call law enforcement if the patient refuses. If necessary you may obtain a court order such as a “no trespass” order or a restraining order that will bar the patient from your practice. During the notice period while the patient finds another physician, you may need to make arrangements to see the patient at a safe location such as an emergency room, should he or she require treatment.

If the patient is served by a mental health agency or other social support agency, you can request that the patient not come to your office without one or more staff persons from the agency accompanying the patient.

A practice should also consider developing an office policy on acceptance or termination of patients. The policy could include examples of reasons for refusing to accept or for terminating a patient such as:

  • The patient is displaying hostility or inappropriate behavior to staff, physicians or other patients;
  • The patient is refusing to cooperate with staff in diagnosis or treatment, or refusing to follow treatment instructions;
  • The physician or staff is unable to communicate effectively with the patient; or
  • The patient is making unreasonable demands on staff or physicians.

The policy should clarify the process for providing notice of termination to patients and should also clarify that the practice will continue to comply with ethical and legal requirements including:

  • Providing care in an emergency;
  • Continuity of care; and
  • Prohibition of discrimination on basis of race, creed, color, national origin, marital status, sex or sexual orientation.

 

Duty to Warn

 

When am I required to disclose patient information to prevent harm?
The duty to warn is an exception to the patient privilege, which has evolved in case law in Vermont and other states. It involves the circumstance where a psychiatrist or other mental health professional has good reason to believe that his or her patient intends to commit physical harm to another individual and will actually do so. If this is the case, the psychiatrist has a duty to take action to avoid such harm to another person, even if it requires the disclosure of confidential medical information. It is probable that the Vermont Supreme Court would extend this duty to other types of practitioners, particularly since the HIPAA exemption discussed below is broader than mental health.

The duty to warn exception originated in California with the case of Tarasoff v. Regents of the University of California, 131 Cal. Rptr., 551 P.2d 334 (1976). In Tarasoff, a university hospital psychologist was told by his patient that the patient intended to kill a woman, Tatiana Tarasoff. Two months later, he did so. The Supreme Court of California ruled that the “public policy favoring protection of patient-psychotherapist communications must yield to the extent to which disclosure is essential to avert danger to others.” [551 P.2d at 347]

In 1985, Peck v. Counseling Service of Addison County [146 Vt 61 (1985)], the Vermont Supreme Court adopted the Tarasoff ruling and extended it, in a case where a patient threatened and did burn down his father’s barn. The court ruled that a mental health professional has a duty to “exercise reasonable care” to protect identifiable victims from a serious risk of danger, and that disclosure of a patient’s threats are not prohibited by the physician-patient privilege established in Vermont statute [18 VSA Section 1612 (a)].

How do I determine if the patient has an actual intent to harm?
Vermont law places the burden on mental health professionals to determine whether the various threats of their patients may reasonably be fulfilled and if so, to act to protect the third persons involved. Comments about harming someone need to be analyzed to distinguish fantasy from situations where an actual intent to harm has been formed. Questions to consider include:
 

  • Does the patient have a specific victim?
  • Does the patient have the means to follow through with an act? Does he or she have access to a gun or other weapon?
  • Is there a specific plan?

If the answers to the above questions are yes, the threat must be taken seriously. In almost all instances, consultation with a colleague is advised to determine the most appropriate course of action given the conflicting duties imposed on the mental health practitioner.

How does the duty to warn relate to HIPAA privacy requirements?
The federal privacy rule, unlike Vermont law, does not create a duty to warn or mandate disclosure. However, Section 164.512(j) of the HIPAA Privacy Rule permits a covered entity to use and disclose protected health information -- including psychotherapy notes -- if the covered entity believes, in good faith, that the use or disclosure is necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public. In this situation, medical records and psychotherapy notes may be disclosed without authorization or consent of the patient. The disclosure must be made to a person or persons reasonably able to prevent or lessen the threat or to the target of the threat. The disclosure must be limited to the minimum amount of information necessary to prevent the harm from occurring.

For more information, go to:
http://www.hhs.gov/ocr/AdminSimpRegText.pdf

Sources/Resources:

  • Vermont Health Information Privacy Issues: Compliance Challenges Under the HIPAA Regulations, Volume I, May 17, 2002, Anne Cramer, Madeleine Mongan, Meg O’Donnell, David Sobel, Frank Fontana

  • Tarasoff v. Regents of the University of California, 131 Cal. Rptr., 551 P.2d 334 (1976).

  • Peck v. Counseling Service of Addison County, 146 Vt 61 (1985)

  • Standards for Privacy of Individually Identifiable Health Information, 64 CFR §164.512 (j)

http://a257.g.akamaitech.net/7/257/2422/05dec20031700/
edocket.access.gpo.gov/cfr_2003/octqtr/pdf/45cfr164.512.pdf

 

Residents’ Rights (Long-Term Care Setting)
Both the federal and Vermont governments have adopted and passed certain regulations that promote quality care in nursing facilities. Under these regulations, all nursing facilities are required by law to have written policies called the Nursing Home Residents’ Bill of Rights. These rights were implemented to protect the resident from abuse and neglect and to provide the resident with an opportunity to participate in his or her care.

There are two components to the Residents’ Bill of Rights: the first is basic human rights; the other is individual rights that are specific to a long-term care setting.

What are some of the basic human rights guaranteed to all nursing home residents?
Every human being has the right to be treated fairly, with dignity, with kindness and respect, and to be free of fear. Violations of these rights may include:

  • Treating residents differently because of race, sex, age, religious beliefs, social status, etc.

  • Allowing other people to be present in the room when personal care is being given without the consent of the resident.
  • Teasing or harassing a resident.
  • Not allowing a resident to freedom to choose the types of activities in which he or she wishes to participate.
  • Withholding treatment, food, mail or any other service.

What are some of the individual rights specific to a long-term care setting?
They include, but are not limited to:

  • The right to be fully informed, prior to or upon admission and during the stay, of the rules of the facility, his or her rights as a resident in the facility, the services with related charges available in the facility, and about Medicare and Medicaid eligibility.

  • The right to choose one’s own personal physician, be fully informed about his or her care and treatment, to participate in planning or changing the care or treatment, and to refuse to participate in experimental research.

  • The right to be free from mental and physical abuse and free from chemical and physical restraints except as authorized in writing by a physician.

  • The right to inspect his or her records, to confidentiality of personal and clinical information, and to approve or refuse their release to any individual outside the facility, except, in case of his or her transfer to another health care institution, or as required by law or third-party payment contract.

  • The right to send and receive mail unopened, to have access to a private use of a telephone, to receive visitors, to voice grievances, to vote, to participate in council meetings, and to manage his or her personal financial affairs.

  • The right to return to the first available bed after hospitalization if the facility is able to meet his or her needs, and to retain his or her bed in the facility while absent due to hospitalization exceeding ten successive days.

  • The right to be informed in writing about availability and eligibility for hospice services. [33 VSA 7301 (2)(B)]

  • The right to professional assessment and management of pain. [33 V.S.A. 7301 (2)(T)]

  • The right to review current and past state and federal survey and inspection reports of the facility.

Violations that would be reported include, but are not limited to:

  • Failure to provide the resident with a copy of his or her rights and responsibilities or any changes made to such rights.

  •  Failure to disclose all cost and charges to the resident.

  •  Not permitting the resident to manage his or her finances.

  •  Restraining a resident, except in an emergency, without an order from a physician.

  •  Discussing a resident’s medical condition with someone who is not involved with the resident’s care.

  •  Not providing the resident an opportunity to review the latest inspection report.

 How are these rights implemented?
The governing body of the facility establishes written policies regarding these rights and responsibilities of residents and, through the administrator, is responsible for the development of and adherence to procedures implementing such policies. All staff of the facility ensures compliance with these rights.

How are these rights communicated to the residents?
The facility is required to post a summary of the obligations of the facility to residents in clear language, in easily readable print and posted conspicuously in a public place on each floor of the facility. The notice shall summarize the facility’s grievance procedure and directions for contacting the ombudsman program. A readable copy of the notice shall be presented to each resident on admission together with an oral explanation of the rights, grievance procedure, and directions for contacting the ombudsman program (Under the federal Older Americans Act, every state is required to have an Ombudsman Program that addresses complaints and advocates for improvements in the long term care system.)

 

What if a right is violated?
When facilities violate these rights, a resident can file complaints with a variety of state and federal agencies. If found in violation of the law, nursing homes, their owners, and administrators can be fined, have their licenses suspended or revoked, and lose their right to payment by Medicaid or Medicare.

If the resident in not capable of understanding these rights, who may exercise these rights on his or her behalf?
These rights and obligations devolve to a resident’s reciprocal beneficiary, guardian, next of kin, sponsoring agency, or representative payee (except when the facility itself is a representative payee) if the resident:

  • has been adjudicated incompetent;
  • has been found by his or her physician to be medically incapable of understanding or exercising the right; or
  • exhibits a communication barrier.

The facility however will make every reasonable effort to communicate the rights and obligations directly to the resident.

Sources/Resources:

  • The Vermont Residents’ Bill of Rights: 33 V.S.A § 7301 et seq.

http://www.leg.state.vt.us/statutes/fullchapter.cfm?Title=33&
Chapter=073

  • The federal Residents’ Bill of Rights: 42 CFR § 483.10

http://a257.g.akamaitech.net/7/257/2422/14mar20010800/
edocket.access.gpo.gov/cfr_2002/octqtr/pdf/42cfr483.10.pdf

 

Patients’ Rights (Hospital Setting)
Vermont has adopted and passed legislation that establishes certain rights for an individual who is an inpatient at a Vermont hospital.

What are some of these rights?
These include, but are not limited to, the right to:

  •  Considerate and respectful care.

  • Obtain current and understandable information about his or her diagnosis, treatment and prognosis.

  • Be informed of the name and position of the doctor in charge of the care.

  •  Receive all the information necessary to give informed consent for any proposed procedure or treatment.

  •  Refuse treatment and be told what effect this may have on the patient’s health.

  •  Privacy while in the hospital and confidentiality of all information and records regarding the care.

  •  Receive all reasonable medical services provided by the hospital, at the request of the physician.

  •  Receive an itemized bill and explanation of all charges.

  •  Know what hospital rules and regulations apply to his or her conduct as a patient.

  •  Professional assessment and management of pain. [18 V.S.A. 1852 (a)(16)]

  • Written information about availability of and eligibility for hospice services. [18 VSA 1852 (a)(17)]

 Violations that would be reported include, but are not limited to:

  •  Failure to provide the patient with a summary of these rights.

  •  Failure to supply information on the medically significant risks associated with a specific procedure.

  •  Discussing a patient’s medical condition with someone who is not involved with the patient’s care without permission of the patient.

How are these rights communicated to patients?
A summary of the hospital’s obligation is distributed to each patient upon admission. The notice shall include that the patient may contact the licensing agency or the Board of Medical Practice and the notice shall include their addresses and phone numbers. Also, the summary must be posted conspicuously at each nurse’s station throughout the hospital.

 

What if a right is violated?
Failure to comply with any of these rights may constitute a basis for disciplinary action against a physician. A complaint may be filed with the Board of Medical Practice.

Sources/Resources:

  • The Bill of Rights for Hospital Patients can be found in: 18 VSA §1851 et seq.

http://www.leg.state.vt.us/statutes/fullchapter.cfm?Title=18&
Chapter=042

 

Reporting to DMV

Are physicians obligated to report a patient to the Department of Motor Vehicles if the patient seems unfit to drive?
There is nothing in the Vermont law that either authorizes or requires physicians to report drivers to the Department of Motor Vehicles, unless the driver poses such a serious threat that the threshold for the duty to warn is met.

The duty to warn under Vermont case law (Peck v. Counseling Service of Addison County) requires health care professionals who know or should know that a patient poses a serious risk of danger to warn potential victims and exercise reasonable care to protect them. The HIPAA Privacy Rule permits, but does not require, disclosure of a serious and imminent threat to the health or safety of a person or the public, without authorization. The disclosure must be based on a good faith belief that disclosure is necessary to prevent the threatened harm from occurring. The disclosure may only be made to someone who is able to prevent or lessen the threat and disclosure. [45 CFR § 164.512 (j)]

The Vermont Department of Motor Vehicles advises any person with concerns about an individual’s driving, including a doctor, family member, or neighbor to request writing that a patient be reexamined by the Department of Motor Vehicles. The Department will schedule relevant examinations including, if appropriate, a medical examination.

The examination request should be sent to:
Vermont Department of Motor Vehicles
120 State Street
Montpelier, VT 05603-0001
Attention: Driver Improvement

Physicians need to balance the duty of confidentiality to their patient with the duty to warn when there is a serious and imminent risk of harm.

Sources/Resources:

  • Vermont DMV Administrative Procedures – #14. Fainting Spells, Blackouts or Other Periods of Unconsciousness

  • AMA Ethical Opinion E-2.24 Impaired Drivers and Their Physicians

http://www.ama-assn.org/apps/pf_new/pf_online?f_n=browse&doc=policyfiles/HnE/E-2.24.HTM&&s_t=&st_p=&nth=1&prev_pol=policyfiles/HnE/E-1.02.HTM&nxt_pol=policyfiles/HnE/E-2.01.HTM&

  • Universal Medical Evaluation/Progress Report (DMV Form)

http://www.aot.state.vt.us/dmv/documents/TA/VS/Tavs113.pdf

  • Peck v. Counseling Service of Addison County, 146 Vt 61 (1985)

  • Standards for Privacy of Individually Identifiable Health Information, 45 CFR §164.512(j)

http://a257.g.akamaitech.net/7/257/2422/05dec20031700/
edocket.access.gpo.gov/cfr_2003/octqtr/pdf/45cfr164.512.pdf

 

Professional Courtesy


What constitutes professional courtesy?
Traditionally, “professional courtesy” has meant waiving the entire fee for the services a physician provides to office staff, other physicians, or other physicians’ families. It has also come to mean waiving coinsurance or co-pay requirements.

 

Is professional courtesy legal?
Yes. New interim final self-referral rules that went into effect in the summer of 2004 (as part of the Stark II rules governing conflicts of interest in physician referrals) create an explicit professional courtesy exception that allows doctors to provide free or discounted care to other physicians or their families. American Medical Association (AMA) Opinion H-140.938 also reaffirms a physician's right to provide professional courtesy. However, if not done carefully, such actions can violate federal anti-kickback statues, the Stark II Act, the False Claims Act or health plan contract obligations. AMA Opinion 6.12 states that physicians should ensure that their policies on waiving co-payments are consistent with applicable law and with the requirements of their agreements with insurers.

 

How do I decide what practices are allowed?
In determining whether a professional courtesy arrangement is allowed, regulators would weigh how the recipients of professional courtesy are selected and how the courtesy is extended.

First, to comply with the Stark II exception, physicians must have a written professional courtesy policy that is approved by the practice's governing body, if applicable. 

Second, physician practices may not select recipients of professional courtesy in a way that is directly or indirectly reflective of the recipient’s ability to generate referrals for the physician. Stark II self-referral regulations clarify that the discount must be offered to all physicians and family members regardless of the business generated between the physicians.

Third, the Stark II interim final rules clarify that professional courtesy may not be offered to beneficiaries of federal health care programs such as Medicare, unless there is genuine financial need. Physician practices should thoroughly document the criteria used to determine such need and should not routinely waive Medicare copayments or coinsurance.

Finally, the physician must keep in mind contractual obligations that specific health plans may have regarding waiving or collecting co-insurance. If professional courtesy involves a reduction of a coinsurance obligation, the Stark II rules state that insurers must be informed in writing of the reduction. 

Sources/Resources:

  • OIG Compliance Program for Individual and Small Group Physician Practices, Federal Register, October 5, 2000 (65 FR 59447)

http://oig.hhs.gov/authorities/docs/physician.pdf

  • Medicare/Medicaid Anti Kickback Statue, 42 U.S.C. §1320a-7b(b)

  • Stark II Rule, (Physician Self-Referral Act, Section 1877 of the Social Security Act)

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=7f67da360f5dde571d4fc6614a4e0942&rgn=
div8&view=text&node=42:2.0.1.2.11.10.35.8&idno=42

  • AMA Ethical Opinion 6.12, "Forgiveness or Waiver of Insurance Copayments."

http://www.ama-assn.org/apps/pf_new/pf_online?f_n=browse&doc=policyfiles/HnE/E-6.12.HTM&&s_t=&st_p=&nth=1&prev_pol=policyfiles/HnE/E-5.09.HTM&nxt_pol=policyfiles/HnE/E-6.01.HTM&

  • AMA Ethical Opinion 6.13, “Professional Courtesy.”

http://www.ama-assn.org/apps/pf_new/pf_online?f_n=browse&doc=policyfiles/HnE/E-6.13.HTM&&s_t=&st_p=&nth=1&prev_pol=policyfiles/HnE/E-5.09.HTM&nxt_pol=policyfiles/HnE/E-6.01.HTM&

 

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About the Author & Editor
Jessa (Block) Barnard was the policy specialist for the Vermont Medical Society from 2002 to 2005. She graduated summa cum laude from Dartmouth College in 2002 with a major in Anthropology and minor in Neuroscience. She is currently attending Stanford Law School.

Madeleine Mongan is counsel and vice president for policy for the Vermont Medical Society, representing the interests of the physicians who live and practice in Vermont.  She works with the Vermont Legislature, state agencies and insurers on health care policy and provides education and technical assistance to Vermont physicians on legal issues.  Her practice addresses a range of health law issues including confidentiality, licensing, managed care, public health, contracting, and fraud and abuse. She represents Vermont physicians on the steering committee of the Vermont Bar Association Drug Policy Committee, the Area Health Education Centers Advisory Board, and the Vermont Health Resource Allocation Plan Board.  She is a member of the American Health Lawyers Association and the Vermont Bar Association where she co-chairs the Health Law Committee.  She received her B.A. from the University of Delaware, M.A. from Stanford University and J.D. from the University of California at Davis.

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