Speakers from trade and physician associations used the board's public comment period to urge careful, state‑specific study of health‑sector consolidation and to highlight factors driving consolidation.
Katarina LaMarche, policy director at the Washington State Hospital Association, told the board that while comparing state laws to other states is useful, Washington already has pretransfer notification laws for hospitals and should first "better understand Washington's healthcare landscape and where the problems are and then apply policy solutions that address the gaps or needs in this state." She urged the board to consider a Washington‑specific study using APCD and other state data.
Jeb Shepherd, representing the Washington State Medical Association, asked the board to allow time to evaluate recently expanded pretransfer notification under House Bill 2548 and to include a dedicated section on upstream cost drivers in the board's report. Shepherd told the board independent physician practices are under stress and said they have "experienced a 40% increase in B and O tax since 2019," a factor he said contributes to closures and affiliations.
Both commenters urged the board to consider the state's existing statutory groundwork and to ensure that any recommendation is tailored to Washington's data and legal context rather than adopted wholesale from other states.