Powell, Bonnie -- FL

Document ID: CMS-2011-0131-0308
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: 80ec814f
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This is comment on Proposed Rule

Medicare Program: Payment Policies under Physician Fee Schedule and Other Revisions to Part B for CY 2012

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I am concerned with the projected financial impact of 2012 CMS proposed rule to expand the multiple procedure payment reduction to include the professional component of advanced imaging services. The radiologists in this practice spend an equal amount of time and skill on interpreting images whether or not they interpret successive imaging studies during a single patient encounter.