Comment from Picard, Michaell, American Society of Echocardiography

Document ID: SSA-2007-0102-0006
Document Type: Public Submission
Agency: Social Security Administration
Received Date: June 16 2008, at 01:51 PM Eastern Daylight Time
Date Posted: June 17 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: April 16 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: June 16 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 80629931
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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

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