Resnick, Stephanie -- GA

Document ID: CMS-2011-0131-0306
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: July 20 2011, at 12:00 AM Eastern Daylight Time
Date Posted: October 12 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: July 19 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: August 30 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80ec6b44
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Concept of 50% pay reduction for radiologist professional fees for studies done the same day is ludicrous. If a patient is in an MVA with multiple injuries, scanning multiple body parts is standard of care. Reading the CT on one body part doesn't meaningfully reduce the work of reading a CT on another body part. Trying to extend the technical component cuts to the professional component simply doesn't make sense. I understand CMS needs to cut reimbursement. But don't penalize the physicians taking care of the sickest patients (trauma, hospital inpatients, ER, cancer patients) by selectively undervaluing their work. If you need to cut rates, why not do a smaller percentage (ie 5%) across the board cut so as not to encourage MD's to cherry pick the healthy cases and leave the sickest patient's for the public hospitals? Also, have you considered the potential barriers to care that may be generated by this rule? Outpatient practices doing non contrast studies may simply limit medicare patients to 1 exam/day. This is a tremendous inconvenience to patients and very inefficient care delivery. It amounts to cost shifting from CMS to the most vulnerable in our society, and will lead to the same discrimination against medicare patients we already see in the family practice/internal medicine setting.

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