Anonymous-CA

Document ID: CMS-2008-0007-0007
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: February 26 2008, at 12:33 AM Eastern Standard Time
Date Posted: July 10 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: January 25 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: March 25 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 803c6e67
View Document:  View as format xml

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I would like to comment on the proposed standard that DMEPOS providers not contract with licensed personnel, ie. Repiratory Therapsit. That these licensed professional now should be staff of the DMEPOS not on a 1099 basis. This is a proposal that seems to be proposed based on the fact that CMS feels that if the licensed professional is part of the staff of the DMEPOS supplier, then the supplier is held more resposnible for the work of the licensed person. Whether the licensed person is part of the staff or not, the work of this person is preferenced by the fact that they do have a license. The state from which the license was issued is reponsible for certifiying that the person is knowledgeable in his or her field. Perhaps an alternative would be to require additional insurance by the supplier to cover the licensed person. As it stands, a proposal such as this will hurt small businesses. These licensed professionals are "professionals" that require professional salaries, which may cause a financial hardship on a small business. The small provider may not do a large annual amount of business in the respiratory area; thus, the licensed professional is used on a 1099 basis. Perhaps an alternative would be to require that the licensed person be a staff member based on a dollar amount. For example, if the supplier reaches $500,000 annually in respiratory reimbursement from medicare, then it would be necessary to have the licensed professional as part of the DMEPOS staff.

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