Mark P. Pollock - Comment

Document ID: FDA-2011-N-0090-0250
Document Type: Public Submission
Agency: Food And Drug Administration
Received Date: November 30 2012, at 12:00 AM Eastern Standard Time
Date Posted: December 3 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: November 19 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: December 19 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 1jw-829r-dmob
View Document:  View as format xml

This is comment on Proposed Rule

Unique Device Identification System; Amendment

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I've been a health care purchasing manager for 35 years at 5 different institutions, from a small 92 bed rural facility to a major university hospital with over 1,000 beds; and I've never experienced, nor heard of from peers, the extra expense and patient dangers alleged by proponents of so-called bad data or incorrect product numbers. I've read all the case studies and articles on the issue, and find no proof there either. I think it only sounds good on an intuitive level, and the only people pushing for this are third party software and portal companies who stand to make more money from the very high implementation costs this rule will cause. The for profit sector already accounts for our very high cost of health care compared to every other country in the world. Please do not add to this problem without being very sure of a net negative cost result. Thanks.

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