Comment on FR Doc # 2010-18924

Dear Secretary Sebelius, I'm writing to support regulations allowing for direct payment of primary care medical practices in conjunction with "wrap-around" insurance for those seeking insurance coverage in the developing insurance exchange. This service promises to reinvigorate the practice of primary care medicine in the US. After working for 28 years in a community clinic serving low income, I moved to Qliance 14 months ago. We don't accept insurance payments even when our patients have insurance. Instead, we charge a monthly fee that is based on age. This ranges from $44 to $74 per month. With this, my patients can see me as often as they need or want without further charge. I'm seeing a mixed group of employer group employees but attract a large number of chronically ill people who see this arrangement as the most cost effective way to access primary care services. In addition, we get to spend an hour with new patients and 30 min. with return visits. To maintain access, we limit patient panel size to 800/doctor. This model would not be possible under fee-for-service charges as the cost of billing prohibits this type of low panel size. I urge you to write regulations that are based on the legislation passed in Washington State allowing this type of practice and that distinguishes it from insurance coverage.