On November 15, 2018, the New York State Society of Plastic Surgeons (NYSSPS), sent a letter to Marcus Friedrich, MD, Chief Medical Officer at the NYS Department of Health, citing concerns regarding the vagueness of the recently released regulations seeking to mandate procedure reports for office-based surgical practices. 

As written, the Society noted that the proposed regulation does not meet the standards of rule making and lacks specificity in how, when and what the NYS DOH will require of practices, making the opportunity for plastic surgeons to provide meaningful comment as to the impact this will have on their practices null and void.

NYSSPS appreciates the opportunity to continue to work with the New York State Department of Health in furthering quality improvement while protecting patients.  However, as written, does not support efforts by the DOH to grant itself broad discretion to define what information OBS practices must report, as well as the form, format and timing of such reports. 

The Society urged DOH to re-publish a proposed regulation that provides the public with a meaningful opportunity to clearly understand the expectations of the department.

NYSSPS Comment Letter
Proposed Regulations