Lee Patterson-NY

Document ID: CMS-2011-0045-0004
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: April 19 2011, at 12:00 AM Eastern Daylight Time
Date Posted: April 21 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: April 4 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: June 3 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80c2f831
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As an owner of an O & P facility operating in the same location for the past 29 years and participating with Medicare/Medicaid; I cannot believe CMS does not enforce the rules they already have mandated. In our small town we have a competitor (part. w/ Medicare,) located in a basement of a PT office and present in the office only a few hours a week. We by contrast have a 5,000' facility with exam rooms, lab, offices, open M-F. So we are losing business because they have a much smaller overhead expense and spend all their time pursuing patients at nursing home etc. We find this unfair and exasperating. As for the certain square footage requirements, to participate with CMS you should have a large enough facility to accomplish all activities associated with O&P including a LABORATORY. These O&P satellite offices located all over the US are just offices who ship out to central fab. How is this best for the O&P patients?

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