SB 1508, An Act Concerning Medical Records

TESTIMONY OF THE CONNECTICUT HOSPITAL ASSOCIATION
SUBMITTED TO THE PUBLIC HEALTH COMMITTEE

Monday, March 17, 2025

The Connecticut Hospital Association (CHA) appreciates this opportunity to submit testimony concerning SB 1508, An Act Concerning Medical Records. CHA generally supports the bill but seeks a clarifying revision, which is outlined below.

Connecticut hospitals and health systems care for patients, strengthen the state’s economy, and support vulnerable communities across the state. Every day, they work to improve healthcare access, affordability, and health equity. Even as they face ongoing challenges, hospitals provide world-class care to everyone who walks through their doors, regardless of their ability to pay. Hospitals also support an exemplary workforce as the largest collective employer in the state, contribute significantly to the state’s economy, and invest in their communities addressing social drivers of health.

SB 1508 seeks to update medical record fees allowed in Connecticut. The current record fee schedule framework was developed over 30 years ago and is out of step with other states’ similar laws. The legal aspects of identity verification, sensitive record issues, and HIPAA compliance make medical records handling a labor-intensive, sophisticated activity that requires skilled professionals to perform the work correctly.

Many of Connecticut’s records laws are out of date and no longer best serve patients or providers. Fixing the fee structure is a good first step. While technologies have made medical records more robust and more actionable for patient care, the process of responding to medical record requests has become increasingly complicated and costly for providers because of the myriad legal requirements designed to protect patient privacy, including but not limited to HIPAA compliance.

We would like to raise one technical point. Lines 85-90 of the bill seek to require the Department of Public Health (DPH) to adjust the per-page record rates. We believe it would be more accurate to indicate that the department needs only to post the rates.

The rates would be adjusted by statutory mandate (and operation of law). This could be accomplished by revising lines 85-91 to read:

Beginning January 1, 2026, and annually thereafter, the per-page fees prescribed in subparagraph (B) of this subdivision shall be adjusted based upon the consumer price index for all urban consumers as determined by the United States Department of Labor, Bureau of Labor Statistics. The Department of Public Health shall annually post the adjusted rates on the department’s Internet web site.

With that clarification, SB 1508 would modernize the medical records fees law, and CHA would unequivocally support the bill.

Additionally, CHA welcomes ongoing discussions with the committee focused on how to improve other aspects of medical information exchange and privacy.

Thank you for your consideration of our position. For additional information, contact CHA Government Relations at (203) 294-7301.