John Bumb-CA

Document ID: CMS-2011-0122-0008
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: June 16 2011, at 12:00 AM Eastern Daylight Time
Date Posted: June 20 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: June 8 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: August 8 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80e50c45
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At a time when physicians are struggling to keep up with the MANY changes occurring under healthcare reform that are forcing many physicians to question their future in medicine or willingness to tolerate Medicare, is it wise to force upon physicians yet another issue that has significant potential to be complex, cumbersome, onerous and potentially very expensive. - As a medical group manager, I'm unable to get traction with commercial insurance programs to report accurate data on our physicians. That is even when I get attorneys involved. It is simply unwise and flat wrong to subject ALL physicians to this scrutiny. - CMS could accomplish the same goal by publishing data on three basic groups. One group representing a carrot and the other, a stick. - Specifically, they would be represented by what CMS reasonably determines are physicians falling under a baseline of what currently represents 10% of the worst physicians. This data could become public. - The second group would be comprised of a current baseline of physicians that are in danger of falling into the worst category. These physicians would be notified privately by CMS of their danger of falling into the first category, provided reasons for such action and way to improve. - The carrot would be to get into the 3rd category and published as a top 5% or 10% physician. - All other physicians in between these groups would receive recommendation on how to improve and score better. All physicians except those failing the grade would then be able to better focus on medicine than focus on the prospect of dealing with a potentially very distracting situation that will only serve to diminish any attractiveness or willingness that may remain with being a Medicare provider. - I have the luxury of consultants and attorneys to help, but how can probably 80%+ of the physicians begin to deal with proposals such as this in a positive manner that serves the public interest?

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