MD

Document ID: CMS-2011-0130-0546
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: November 30 2011, at 12:00 AM Eastern Standard Time
Date Posted: May 23 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: November 30 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: January 3 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 80f773be
View Document:

This is comment on Rule

Medicare and Medicaid Programs: Hospital Outpatient Prospective Payment; Ambulatory Surgical Center Payment; Hospital Value-Based Purchasing Program; Physician Self-Referral; and Patient Notification Requirements in Provider Agreements

View Comment

The refilling and reprogramming of an intrathecal pump is a high risk procedure requiring a significant amount of knowledge and skill. Mistakes in either the refill process or the re-programming of these pumps can result in significant injury to the patient to include meningitis or death. These procedures require a significant amount of one on one time by the practitioner and there is actually no procedure that even remotely compares to be able to suggest that the current coding is "too high compared to similar services in this family." There are no similar services of drug delivery directly into the spinal fluid. My nurses and physicians have been doing this for fourten years and we are not able to get the whole one on one process below 30-45 minutes and maintain patient safety. What seems similar is in fact, not at all. It is my opinion, as a long time pain management nurse , that this needs careful re-consideration.