Brent King--TX

I am concerned that an unintended consequence of this rule will be to make it virtually impossible for resident physicians and fellows to order diagnostic procedures, testing, and consults for Medicare enrollees. Physcians in training, under the supervision of attending physicians, provide exceptional care in a very cost-efficient fashion. To require that every order on a large teaching service be written by an enrolled physician (i.e. an attending) or a mid-level provider, will place a considerabe financial burden upon teaching hospitals and medical schools, many of which are already struggling financially. Such facilities will be required to have a large cadre of Medicare enrolled physicians or mid-level providers available at all hours. Additionally, this kind of control further dilutes the training experience of resident physicians. Residents and fellows learn through a process of progressively increased responsibility. Under this rule, they will be unable to independently order even the simplest diagnostic test. Residents and fellows who are reasonably well supervised will not deliver most costly care than fully trained physicians but poorly trained residents; those who have never had to think independly will become very costly providers because they will try to compensate for their lack of clinical judgment with over-testing.