Medical and Nursing Licensure in Connecticut in the COVID-19 Crisis

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March 25, 2020

By: Cody N. Guarnieri, Esq

In the midst of a state and national emergency of unprecedented proportions, the State of Connecticut has taken measures to reduce the barriers to the practice of medicine by health care professionals duly licensed in other jurisdictions. Earlier this week an order by the Commissioner of the Department of Public Health Reneé D. Coleman-Mitchell, MPH. This order was issued under the Commissioner's authority to act in light of Governor Lamont's March 10, 2020, declaration of a public health and civil preparedness emergency.

In brief, the Commissioner's order temporarily suspends, for up to sixty days unless extended, the requirements of licensure, certification or registration for health care professionals in the State of Connecticut for certain professionals who are duly licensed, registered or certified in another state of United States territory. The medical license, certification or registrations types included in this order are:

  • Emergency Medical Services
  • Medicine and Surgery
  • Physical Therapists
  • Nursing
  • Nurse's Aides
  • Respiratory Care Practitioners
  • Psychologists
  • Marital and Family Therapists
  • Clinical Social Workers and Master Social Workers
  • Professional Counselors
  • Emergency Medical Services Personnel
  • Pharmacy

In addition to being duly licensed, certified and/or registered in another state, medical professions practicing in Connecticut are also subject to further direction by the Commission. Briefly, these further directives include that medical providers operating under this order (1) only practice within the scope of their medical profession (as described in the licensure provisions of the General Statutes), (2) carry the same quality and quantity of malpractice or liability insurance as would be required a Connecticut licensed, certified or registered provider and (3) entities employing or contracting with out-of-state providers under this order verify their credentials in their home state and their insurance coverage

Moreover, the order also describes the impact of insurance on out-of-state providers under this order. First, providers enrolled in Medicaid or a fully insured commercial plan accept those payments as full compensation. If not operating under Medicaid or a full insured commercial plan, the out-of-state provider is obligated to determine if the patient has any other form of insurance coverage before providing services. If so, the provider must accept the health plan reimbursement as payment in full and not charge the patient anything additional. If the patient is not insured, or the service is not covered, the out-of-state provider must accept the Medicare rate for that service as payment in full. If the patient is not insured and unable to pay, the provider must provide services that he or she would be required to provide under state or federal law.

With the COVID-19 pandemic, this is a time of great uncertainty. This uncertainty is not only for patients, but for providers as well. As the medical community rallies to be of assistance in light of the unprecedented health crisis, barriers between licensing jurisdictions are becoming blurred. Where there is uncertainty, there is also risk. If you are a healthcare provider who has questions about your Connecticut licensure or ability to practice your profession in Connecticut, contact me to discuss.