NAFEC Opposed Rhode Island's SB 2696

April 25, 2016

Senator Joshua Miller

Rhode Island Senate

82 Smith Street

Providence, RI 02903


Senator Miller,

On behalf of our members operating freestanding emergency centers across the country, the National Association of Freestanding Emergency Centers (NAFEC) OPPOSES SB 2696.

NAFEC represents the unique interests of freestanding emergency centers (FECs) delivering emergency medicine outside of the traditional hospital setting. NAFEC advocates for fair regulation and raises awareness of FECs as a high-quality, accessible, emergency medical care option.

NAFEC believes that existing statutory criteria are met when a facility in Rhode Island completes a rigorous license hearing process with the result being a license issued. NAFEC OPPOSES legislation as an attempt to go backwards by creating a new CON process. Many states have moved to abolish the CON process which favors existing entities, limits competition, provides a monopoly and eliminates patient choice. Free markets should be free and allowable. 

The Antitrust Division of the U.S. Department of Justice and the U.S. Federal Trade Commission, in a joint statement, noted that CON laws “impede the efficient performance of health care markets” and “pose serious anticompetitive risks that usually outweigh their purported economic benefits”.

NAFEC believes that the current process works and questions whether adding the criteria parameter improves a process that was just proven to work.

Please do not hesitate to contact me with any questions or for further assistance. 



Brad Shields

NAFEC Executive Director