June 16, 2008
Michael J. Astrue
Commissioner
Social Security Administration
P.O. Box 17703
Baltimore, MD 21235-7703
RE: SSA-2007-0102
Revised Medical Criteria for Evaluating Cardiovascular Disorders
Dear Commissioner Astrue,
The American Society of Echocardiography (ASE) is pleased to submit
comments on the Advance Notice of Proposed Rulemaking entitled “Revised
Medical Criteria for Evaluating Cardiovascular Disorders” published in the Federal
Register on April 16, 2008 (the “Criteria”). The ASE is an organization of over
13,000 physicians, cardiac sonographers, and other professionals committed to
excellence in cardiovascular ultrasound and its application to patient care. ASE
supports this mission through education, advocacy, research, innovation and
service to our members and the public.
The ASE agrees with the ACC and the AHA that the Criteria as currently written
do not reflect current medical practice and do not provide adequate guidance to
the SSA in making disability determinations for individuals with cardiovascular
impairments, and strongly concur with the comments filed by the ACC and the
AHA on this issue. In addition to the ACC/AHA guidelines referenced in the
ACC/AHA comment letter, we would like to call to the SSA’s attention the
guidelines adopted by the ASE, which are found at
http://www.asecho.org/Guidelines.php, and suggest that the SSA review these
guidelines and incorporate them, as appropriate in the revised Criteria that we
understand will be published in proposed form in the Federal Register for comment
in the future.
We appreciate the opportunity to submit our input on this important SSA
initiative. Please do not hesitate to contact ASE staff, Cathy Kerr ((919) 861-
5574 x223; ckerr@FirstPointResources.com), if you have any questions or need
any assistance.
Sincerely,
Michael Picard, MD
Co-Chair
ASE Advocacy Committee
Comment from Picard, Michaell, American Society of Echocardiography
This is comment on Proposed Rule
Revised Medical Criteria for Evaluating Cardiovascular Disorders
View Comment
Related Comments
Public Submission Posted: 06/17/2008 ID: SSA-2007-0102-0003
Jun 16,2008 11:59 PM ET
Public Submission Posted: 06/17/2008 ID: SSA-2007-0102-0004
Jun 16,2008 11:59 PM ET
Public Submission Posted: 06/17/2008 ID: SSA-2007-0102-0005
Jun 16,2008 11:59 PM ET
Public Submission Posted: 06/17/2008 ID: SSA-2007-0102-0006
Jun 16,2008 11:59 PM ET
Public Submission Posted: 06/13/2008 ID: SSA-2007-0102-0002
Jun 16,2008 11:59 PM ET