August 20, 2021
James Frederick
Acting Assistant Secretary of Labor
Occupational Safety and Health Administration
U.S. Department of Labor
200 Constitution Avenue NW
Washington, D.C. 20210
Electronically submitted via www.regulations.gov
Re: Occupational Exposure to COVID-19; Emergency Temporary Standard
Dear Acting Assistant Secretary Frederick,
On behalf of our member medical group practices, the Medical Group Management Association (MGMA) writes to express our shared commitment to protect healthcare workers from contracting COVID-19. While we appreciate that the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) is attempting to protect healthcare workers through the COVID-19 healthcare emergency temporary standard (ETS), we believe the ETS was issued much too late and as a result, will disrupt the ongoing efforts of medical groups to balance the needs of patients against the imperative to protect employees.
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