Comment from Rackers, Myra, Missouri Disability Determinations

We basically agree with the proposed changes in the NPRM. We believe the requirement for length of hospitalization for asthma exacerbation should be 48 hours OR 2 overnight stays, the latter may not be quite 48 hours but would be equivalent. These revisions would be very welcome/helpful. Simplifying the requirements for documentation for acceptable PFS test and saving CE $ is a plus. Excluding exercise ABGs(rarely if ever ordered) is a positive change. Adding Pulse Ox is positive but it will now require additional documentation. It looks like they are adding other tables for PFTs based on age and gender and a special table for those 18-20. They are taking out listings such as pneumoconiosis and having them evaluated under 3.02 which is ok as long as they state specifically that this impairment and the others by name should be evaluated under 3.02. I believe it said it would.