PA

While I applaud CMS for taking steps to address this issue, the proposed regulations are excluding teleradiology providers ("nighthawk"). Many of these teleradiology providers are not "Medicare-participating hospitals" as required under the proposed rule. Many are JCAHO accredited organizations, but they are not hospitals. As correctly noted in the proposed rule, credentialing of these service providers is exceptionally difficult for many small, rural hospitals that utilize their services. I believe you will find that many small hospitals are forced to utilize "nighthawk" services due to limited availability of qualified radiologists, especially after hours. I respectfully request that CMS include teleradiology providers, especially those that are Joint Commission accredited organizations. Otherwise, the proposed regulations will be of little or no assistance to small hospitals. Thank you.