anonymous

File Code: CMS-3267-P Radiology Services in Ambulatory Surgery Centers I am glad to have this regulation addressed as this has been overly burdensome to the ASC's and this regulation has not been consistently applied across surveyors. My concern is the language in the proposed regulatory body pertaining to the operating surgeon "as part of his or her qualifications in order to be privileged to perform the procedure, to DEMONSTRATE COMPETENCY in using imaging as an integral part of the procedure. By virtue of their training physicians are trained and competent to read and interpret x-rays for the surgeries in which they perform. How exactly would they need to DEMONSTRATE (as this is an action verb) their competency? I am also concerned regarding the language ".....requirement that an MD/DO who is qualified by education and experience in accordance with State law and ASC policy must SUPERVISE the PROVISION of RADIOLOGIC SERVICES." Please define "radiologic services". Radiologic services to me encompasses more than just overseeing x-rays being taken. To me this includes the monitoring of dosimetry badges, annual physicist visits to inspect the c-arm, annual lead shielding integrity checks etc.- these are areas in which physicians are not familiar with and it may be difficult in a small ASC to find a physician willing to take on the legal requirements of overseeing "readiologic services." I would instead recommend requiring individual physicians who use imaging equipment be "privileged" to provide and/or oversee the taking of x-rays and interpretation of the results.