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October 15, 2014

Anna Marie Sossong
Deputy Secretary - Quality Assurance
Office of Quality Assurance
Pennsylvania Department of Health
8th Floor West, Health & Welfare Building
625 Forster Street
Harrisburg, PA 17120-0701

RE: Proposed Regulations—Photo Identification Badges

Dear Ms. Sossong:

The Hospital & Healthsystem Association of Pennsylvania (HAP), on behalf of its members, more than 225 acute and specialty hospitals and health systems, appreciates the opportunity to comment on the Department of Health’s (DOH) photo identification badge proposed regulations. Identification of health care personnel ensures patient safety and HAP appreciates DOH’s efforts on this behalf.

Since 1998, with the inclusion of identification badge requirements under Chapter 51 of DOH’s health care facility regulations, Pennsylvania hospitals and health systems have demonstrated compliance to ensure patient safety. As part of the identification process, most hospitals included photos on their identification badges, even though including a photo was not a requirement under Chapter 51.

HAP appreciates that DOH had addressed our previous comment regarding our concern for personal security as a result of the full name requirement. HAP’s concern focused on those patients that have no history of irrationality or violence, but can become this way during their visit or in a future visit. HAP appreciates that DOH recognizes the need to protect Pennsylvania’s health care providers by allowing for the omission of the employee’s last name on the identification badge. HAP supports the provision that facilities are to establish policies and procedures for an exceptions process to allow for any unique circumstances that may arise.

However, we remain very concerned about the requirement that mandates that photos be renewed every four years. Establishing this requirement because it is consistent with the requirements for photographic driver’s licenses is not an appropriate justification nor is it an appropriate comparison. Individuals pay for the privilege of having a driver’s license. Hospitals bear the cost of providing identification badges for their employees.

Providing identification badges is an investment in time and financial resources for health care facilities. As hospitals have increasingly used the identification badges to meet other meaningful and useful purposes related to patient care, the replacement costs for an employee identification badge have increased. Therefore, HAP believes that Pennsylvania’s hospitals require flexibility to determine how best to identify their employees, as well as, the ability to design identification badges that enable other important purposes that also improve care effectiveness and patient safety.

HAP adamantly opposes the requirement that photos be renewed every four years as hospitals have demonstrated their commitment since 1998 to responsibly identify their employees. Mandating such a time period when photos need to be updated without any documented evidence that this four-year update improves patient safety would impose an undue financial and administrative burden on health care organizations.

HAP believes it is more appropriate for DOH to require hospitals to establish clear policies regarding when photos need to be updated, including but not limited to, a change in name, title, or job, and for such policies to include reasonable time frames to ensure currency of photo identification.

HAP appreciates the opportunity to provide comments on the proposed identification badge regulations. If you have any questions about HAP’s comments, please feel free to contact Mary Marshall, director, workforce and professional services, at (717) 561-5312; or me, at (717) 561-5344.


Senior Vice President
Policy & Regulatory Advocacy

c:  Jamie Buchenauer

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