GENERAL...Anesthesia Coding (Pan of 5-Year Review) Dear Ms. Nonvalk: I am writing to express my...

Submitter : Dr. Mark Ky ker

Organization : Dr. Mark Ky ker

Category : Physician

Issue AreasIComments

Date: 07/16/2007

GENERAL

GENERAL Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS- 1385-P P.O. Box 8018 Baltimore, MD 2 1244-8018

Re: CMS-1385-P

Anesthesia Coding (Part of 5-Year Review)

Dear Ms. Nonvalk:

I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor ta offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.W per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.

To ensure that our patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.

Thank you for your consideration of this serious matter.

Page 4 1 of 547 July 18200703:19PM

Submitter : Dr. Corey Carpenter

Organization : UT Kooxville


Issue AreaslComments

Date: 07/16/2007

GENERAL

GENERAL Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore, MD 2 1244-801 8

Re: CMS- 1385-P

Anesthesia Coding (Pan of 5-Year Review)

Dear Ms. Nonvalk:



In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule. and I support full implementation of the RUC s recommendation.



Dr. Corey Carpenter

Page 42 of 547 July 18 2007 03: 19 PM

Submitter : Gary Perotti

Organization : Washington University School of Medicine

Category : Health Care Provider/Association

Issue Areas/Comments

GENERAL

GENERAL See Awhment

Page 43 of 547

Date: 07/16/2007

July 18 2007 03:19 PM

Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 80 18 Baltimore, MD 2 1244-80 18

Re: CMS-1385-P Anesthesia Coding (Part of 5-Year Review)

Dear Ms. Norwalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation's seniors.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation-a move that would result in an increase of about $4.00 per unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the updated payment.


Submitter : Dr. Paul Zelenkov

Organization : Dr. Paul Zelenkov



GENERAL

Date: 07/16/2007

GENERAL Paul Zelenkov MD 6303 E Stanford Ave Englewood, CO 801 1 1


Dear Ms. Nonvalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away fmm areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s commendation.



Paul Zelenkov MD

Page 44 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Marsha Wakefield

Organization : Dr. Marsha Wakefield



Date: 07/16/2007

Coding- Additional Codes From 5-Year Review

Coding-- Additional Codes From 5-Year Review

Re: CMS- 1385-P Anesthesia Coding (Part of 5-Year Review)

Dear Ms. Norwalk:



In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed mle, and I support full implementation of the RUC s recommendation.

To ensure that ow patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.

Thank you for your consideration of this serious matter. As the primary caretaker for aging parents, it is important to me that my parents and their friends have access to the best anesthesia care regardless of location. This should help decrease the inequity across different geographic areas.

Sincerely, Marsha Wakefield

Page 45 of 547 July 18 2007 03:19 PM

Submitter :

Organization :



GENERAL

GENERAL

see attachment

Page 46 of 547

Date: 07/16/2007

July 18 2007 03: 19 PM

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore, MD 21244-8018

Re: CMS-1385-P Anesthesia coding (Part of 5-Year Review)

Dear Ms. Nonvalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation's seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation-a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC7s recommendation.



Submitter : Dr. Robert Morgan

Organization : South Carolina Society of Anesthesiologists



Date: 07/16/2007

GENERAL

GENERAL Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore, MD 21 244-801 8

Re: CMS-1385-P Anesthesia Coding (Pan of 5-Year Review)

Dear Ms. Norwalk:

As President of the South Carolina Society of Anesthesiologists, I am writing to offer my utmost support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. All of our members appreciate that CMS has recognized the massive undervaluation of anesthesia services, and more importantly, that CMS is taking steps to address this complex issue.

At present, Medicare payments do not eover the cost of taking care of our nation's senior citizens. Anesthesiologists are being forced to relocate away from areas with disproportionately high Medicare populations, and recruitment for many groups, including those in our state, is suffering as a result.

We hope that CMS will follow the RUC recommendation to increase the anesthesia conversion factor. Please help us by ensuring that this recommendation is fully implemented so that our patients will have access to the best anesthesiology care that they can have for many years to come.

If you have any questions or if 1 may help in any way, please contact me at 864-238-5893.

Thank you for your consideration.

Respectfully, Rob Morgan, M.D. President South Carolina Society of Anesthesiologists

Page 47 of 547 July 18200703:19PM

Submitter : Dr. Philip Boyle Date: 07/16/2007

Organization : Dr. Philip Boyle



GENERAL

GENERAL

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 801 8 Baltimore. MD 21 244-801 8


Dear Ms. Nonvalk:

I am writing to express my strongest suppon for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.1 9 per unit. This amount does not wver the wst of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effon to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I suppon full implementation of the RUC s rewmmendation.

To ensure that our patients have access to expen anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.

Thank you for your consideration of this serious matter

Page 48 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Julia Pollock

Organization : Virginia-Mason Medical Center


Issue AreaslCommenb

Date: 07/16/2007

GENERAL

GENERAL Leslie V. Norwalk, Esq. Aeting Administrator Centers for Medieare and Medieaid Serviees Attention: CMS-1385-P P.O. Box 801 8 Baltimore, MD 2 1244-80 18


Dear Ms. Nonvalk:

I am writing to express my skongest support for the proposal to inerease anesthesia payments under the 2008 Physieian Fee Sehedule. I am grateful that CMS has reeognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since thc RBRVS took effect, Medicare payment for anesthesia services stands at just $16.1 9 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are W i g forced away fmm areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Page 49 of 547 July 18 2007 03: 19 PM

Submitter : Dr. shelby salmon

Organization : metroanesthesia



GENERAL

GENERAL

Date: 07/16/2007

I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue. THank you for your time.

Dr. Shelby Salmon

Page 50 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Eugene Miller Date: 07/16/2007

Organization : Madison Anesthesiology Consultants,LLP





Leslie Norwalk,Esq. Acting Administrator Centers for Medieare and Medicaid Serviees Atm: CMS 1385-P P.O. Box 801 8 Baltimore,MD 2 1244-801 8

Re: CMS 1385-P Anesthesia Coding (Part of 5 Year Review)

Dear Ms. Norwalk:

I have been an Anesthesiologist for 20 years and am pleased that you are considering increasing anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the undervaluation of anesthesia services and is willing to rectify a longstanding problem.

As you know, anesthesia work has been significantly undervalued compared to other physician services. Our current unit rate does not cover the cost of taking care of our Medicare patients and may limit expert anesthesiology scrvices to those who need it most.

It is imperative that CMS follow through with the proposal in the Federal Register by implementing the anesthesia conversion factor increase as recommended by the RUC.


Eugenc C. Miller M.D.

Page 5 1 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Maria Inton-Santos

Organization : Cleveland Clinic

Category : Individual

Issue AreadComments

Date: 07/16/2007

GENERAL

GENERAL Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 80 18 Baltimore, MD 21244-80 18


Dear Ms. Nonvalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation,s seniors, and is creating an unsustainable system in which anesthesiologists are being f o d away from areas with disproportionately high Mcdicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step fotward in conecting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Page 52 of 547 July 18 2007 03:19 PM

Submitter : Ms. Judith Krafi

Organization : Children's Anesthesiology Associates, Ltd.

Category : Other Health Care Professional


Date: 07/16/2007

GENERAL

GENERAL

Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 801 8 Baltimore. MD 2 1244-80 18


Dear Ms. Norwalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect. Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is cleating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.




Page 53 of 547 July 18 2007 03: 19 P M

Submitter : Dr. Michael Duan Date: 07/16/2007

Organization : Star Anesthesia, PA





Leslie V. Nowalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore, MD 2 1244-8018

Re: CMS-1385-P


Dear Ms. Nonvalk:

1 am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.



To ensure that our patients have access to expert anesthesiology mcdical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Page 54 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Michael O'Reilly Date: 07/16/2007

Organization : University of Michigan



GENERAL

GENERAL July 12,2007

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS- 1385-P P.O. Box 801 8 Baltimore, MD 2 1244-801 8


Dear Ms. Nonvalk:

1 am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors and is creating an unsustainable system in which anesthesiologists are being f o r d away from areas with disproportionately high Medicare populations.

In an effort to improve this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and 1 support full implementation of the RUC s recommendation.


Thank you for your consideration of this important matter.

Michael O'Reilly, M.D. Associate Professor University of Michigan

Page 55 of 547 July 18 2007 03:19 PM

Submitter : Dr. Mario Cancemi

Organization : UTMB


Date: 07/16/2007


GENERAL

GENERAL

I am writing to urge support for the increase in CMS medicare payments for anesthesiologist's reimbursement. Thank you.

Mario Cancemi

Page 56 of 547 July 18 2007 03:19 PM

Submitter : Miss. Susan Lindenbaum Date: 07/16/2007

Organization : Miss. Susan Lindenbaum

Category : Academic


GENERAL

GENERAL Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 801 8 Baltimore, MD 2 1244-801 8


Dear Ms. Norwalk:


When the RBRVS was instituted, it created a hugc payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicarc payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologisa are being forced away from areas with disproportionately high Medicare populations.


To ensure that our patients have access to expert anesthesiology mcdical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Page 57 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Eric Zimmer

Organization : Dr. Eric Zimmer



Date: 07/16/2007

GENERAL

GENERAL 1 Medicare wages must be increased just to keep physicians accepting patients and providing care. I am about to stop seeing medicare patients in my chronic pain practice because the payment is just silly. You have heard about the cost of keeping an ofice, etc and anesthesia fees and pain fees will not sustain anyone's practice

Page 58 of 547 July 18200703:19PM

Submitter : Dr. Lawrence Bauss

Organization : Dr. Lawrence Bauss



Date: 07/16/2007

GENERAL


Re: CMS-1385-P Anesthesia Coding (Part of S-Year Review)

Dear Ms. Norwalk:

I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issuc.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just % 16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medieare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of neady $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule. and I support full implementation of the RUC s recommendation.



Lawrence A Bauss MD

Page 59 o f 547 July 18 2007 03: 19 PM

Submitter : Dr. Timothy Shipe

Organization : Dr. Timothy Shipe



Date: 0711612007

GENERAL

GENERAL



Dear Ms. Norwalk:



In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthcsia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.

To ensure that our patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing thc anesthesia conversion factor increase as recommended by the RUC.


Timothy Shipe MD 1304 Masters CT Chesapeake VA 23320

Page 60 of 547 July 18 2007 03:19 PM

Submitter : Dr. Raymond Hicks

Organization : Univ of Virginia



Date: 07/16/2007

GENERAL

GENERAL

Re: CMS-1385-P


Dear Sirs,




To ensure that o w patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.

Thank you.

Dr raymond H Hicks Univ of VA

Page 61 of 547 July 18 2007 0399 PM

Submitter : Dr. Keith Elmslie

Organization : Penn State College of Medicine



Date: 07/16/2007

GENERAL

GENERAL


Dear Ms. Nonvalk:

I em writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $1 6.1 9 per unit. This amount does not cover the cost of caring for our nation's seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation-a move that would result in an increase of nearly 54.00 per anesthesia unit and serve as a major step fonvard in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC's recommendation.

To ensure that our patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increae as recommended by the RUC.


Sincerely,

Keith Elmslie, Ph.D. Associate Professor of Anesthesiology and Pharmacology Pem State College of Medicine

Page 62 of 547 July 18200703:19PM

Submitter : Dr. Terrance Breen

Organization : Anesthesia Service Medical Group



Date: 07/16/2007

GENERAL

GENERAL Dr. Terrance W. Breen 5503 Rutgers Road La Jolla, CA 92037

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore. MD 2 1244-80 18


Dear Ms. Nonvalk:






Yours truly,

Terrance W. Breen, M.D.

CMS- 1385-P-2527-Attach- I .DOC

Page 63 of 547 July 18 2007 03: 19 PM

Dr. Terrance W. Breen 5503 Rutgers Road La Jolla, CA 92037

Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore, MD 21244-8018


Dear Ms. Norwalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation's seniors, and is creating an unsustainable system in which anesthesiologists are being forced away fiom areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation-a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC's recommendation.



Yours truly,

Terrance W. Breen, M.D.

Submitter : Dr. Tak Liu

Organization : Dr. Tak Liu



Date: 07/16/2007

GENERAL

GENERAL

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-I 385-P P.O. Box 801 8 Baltimore, MD 2 1244-80 18

Re: CMS- 1385-P


Dear Ms. Nonvalk:




To cnsure that our patients have access to expert ancsthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Page 64 of 547 July 18 2007 03: 19 PM

Submitter : Dr. adam haas Date: 07/16/2007

Organization : , Dr. adam haas



GENERAL

GENERAL Leslie V. Nowalk, Esq. Acting Adminisbator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 801 8 Baltimore, MD 21244-80 18

Re: CMS-1385-P


Dear Ms. Nowalk:



In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step foward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Adam J. Haas MD Department of Anesthesiology University Hospitals of Cleveland Case Medical Center 1 l I00 Euclid Avenue Cleveland OHIO 44 106

Page 65 of 547 July 18 2007 03: 19 PM

Submitter :

Organization :



GENERAL

GENERAL

Date: 07/16/2007

Leslie V. Nonvalk, Esq.

Acting Administrator

Centers for Medicare and Medicaid Services

Attention: CMS-1385-P

P.O. Box 8018

Baltimore, MD 2 1244-8018

Re: CMS-1385-P


Dear Ms. Norwalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 (Our local rate is $15.67.) per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicarc populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of neady $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed mlc, and I support full implementation of the RUC s recommendation.



John J. Olson, M.D.

Page 66 of 547 July 18200703:19PM

Submitter : Ms. Rochelle Settlemeyer

Organization : Old Pueblo Anesthesia


Date: 07/16/2007

Issue AreadComments

GENERAL

GENERAL Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Anention: CMS-1385-P P.O. Box 801 8 Baltimore, MD 21244-801 8


Dear Ms. Nonvalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthcsia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in conecting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.

To ensure that our patients have access to expert anesthesiology mcdical carc, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Sincerely,

Rochelle Senlemeyer

Page 67 of 547 July 18 2007 03:19 PM

Submitter : Renee Kreeger

Organization : Renee Kreeger



GENERAL

Date: 07/16/2007

GENERAL

Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS- 1385-P P.O. Box 80 18 Baltimore, MD 2 1244-80 18


Dear Ms. Norwalk:

I am writing to express my sincere support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. The large payment disparity for anesthesia care does not adequately cover the cost of caring for our Medicare patients, and is making it difficult for anesthesiologists to practice in areas with large Medicare populations.

I hl ly support the RUC recommendation that CMS increase the anesthesia conve~sion factor.

Thank you for your consideration and time.

Sincerely, Renee Kreeger

Page 68 of 547 July 18 2007 03:19 PM

Submitter : Dr. Clavio Ascari

Organization : Total Anesthesia



Date: 07/16/2007

GENERAL

GENERAL

I am writing to express my skongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.


In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of tbe RUC s recommendation.



Page 69 of 547 July 18200703:19PM

Submitter : Dr. Matthew VonFeldt

Organization : Dr. Matthew VonFeldt



Date: 07/16/2007

Background

Background

Leslie V. Norwalk, Esq.




P.O. Box 80 18

Baltimore, MD 2 1244-801 8

Re: CMS-1385-P


Dear Ms. Norwalk:

I am writing to express my sbongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.1 9 per unit. This amount does not cover the wst of caring for our nation s senion, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia convcrsion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Matthew VonFeldt, MD

Page 70 of 547 July 18200703:19PM

Submitter : Dr. Raymond Danchak Date: 07/16/2007

Organization : Great Plains Anesthesia



GENERAL

GENERAL

Dear Ms. Norwalk,

Re: CMS 1385P Anesthesia Coding

I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. 1 am grateful that CMS has recognized the gross underevaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue. When the RBRUVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant underevaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRUVS took effect, Medicare payment for anesthesia services stands at just $16.08 per unit in the Lubbock, Texas area. The amount docs not cover the cost of caring for our nation's seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations. In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation-- a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation in itspropsed rule, and 1 support full implementation of the RUC's recommendation. To ensure that our patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC. Thank you for your consideration in this matter.

Sincere1 y Raymond Michael Danchak, MD President Great Plains Anesthesia

Page 7 1 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Sanjay Vanguri Date: 07/16/2007

Organization : Dr. Sanjay Vanguri



GENERAL

GENERAL

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore, MD 21244-801 8

Re: CMS-1385-P Anesthesia Coding (Part of 5-Year Rcview)

Dear Ms. Nonvalk:


When the RBRVS was instituted. it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.1 9 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.




Dr. Sanjay Vanguri

Page 72 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Supriya Jagannath

Organization : Dr. Supriya Jagannath


Date: 07/16/2007


GENERAL

GENERAL

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore, MD 2 1244-80 18


Dear Ms. Nonvalk:



In an effort to rectify this untenable situation, the RUC recommended that CMS increase. the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase. of nearly $4.00 per anesthesia unit and serve as a major step fonvard in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Dr. Supriya Jagannath

Page 73 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Brian Kradel

Organization : Anesthesia Unlimited, Inc.



Date: 07/16/2007

GENERAL

GENERAL

I want to express my strongest support for the proposed increase to anesthesia payments under the ZOOS Physician Fee Schedule. Anesthesia services have been grossly undervalued and we appreciate the plan to correct this huge payment disparity. Continued care for ow medicare recipients will require a substantial increase in the medicare payment for anesthesia services. The current payment of $16.19 per unit often does not even cover our cost for providing the service.

Page 74 of 547 July 18 2007 03:19 PM

Submitter : Dr. milamari cunningham

Organization : Dr. milamari cunningham



Date: 07/16/2007

GENERAL


Re: CMS-1385-P


Dear Ms. Nonvalk:



In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of neady $4.00 per anesthesia unit and serve as a major step forward in comt ing the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Dr. Milamari A. Cunningham retired board certified anesthesiologist

Page 75 of 547 July 18 2007 03:19 PM

Submitter : Mrs. ARACELY MENDEZ

Organization : OLD PUEBLO ANESTHESIA

Category : Health Care Industry

Date: 07/16/2007

Issue AreadComments

GENERAL

GENERAL

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore, MD 21244-8018


Dear Ms. Nonvalk:


Whcn the RBRVS was instituted, it created a huge payment disparity for anesthesia care., mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are beiig forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in comting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Aracely Mendez

Page 76 of 547 July 18 2007 03:19 PM

Submitter : Jean Johnston

Organization : Old Pueblo Anesthesia

Category : Health Care Industry


Date: 07/16/2007

GENERAL

GENERAL

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicarc and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore, MD 2 1244-801 8


Dear Ms. Norwalk:

I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthcsia services, since and that the Agency is taking steps to address this complicated issuc.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to othcr physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $1 6.19 pcr unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionatcly high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of ancsthesia scrviccs. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.

To ensure that our paticnts havc access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Jean Johnston

Page 77 of 547 July 18 2007 03:19 PM

Submitter : Dr. Jason Carter

Organization : Delaware County Anesthesiologists



GENERAL

GENERAL

Leslie V. Nonvalk, Esq.

Date: 07/16/2007




P.O. Box 8018

Baltimore, MD 21244-8018

Re: CMS-1385-P


Dear Ms. Norwalk:

I am writing to express my suongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are k ing forced away from areas with disproportionately high Medicare populations.



Thank you for your consideration of this serious matter. Sincerely, Jason G. Carter, MD Delaware County Anesthesiologists

Page 78 of 547 July 18200703:19PM

Submitter : Dr. Osborne Williams

Organization : Dr. Osborne Williams



GENERAL

GENERAL

see Attachment

CMS- 1385-P-2543-Attach- I. DOC

Page 79 of 547

Date: 07/16/2007

July 18200703:19PM



Dear Ms. Norwalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.1 9 per unit. This amount does not cover the cost of caring for our nation's seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation-a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting .the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC's recommendation.



Osborne D Williams MD NYS LIC 194538

Submitter : Dr. Mary Fillinger

Organization : American Society of Anesthesiologists



Date: 0711 612007

GENERAL

GENERAL

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Mcdicaid Services Attention: CMS- 1385-P P.O. Box 8018 Baltimore. MD 21244-801 8

Re: CMS-1385-P

Anesthesia Coding (Part of.5-Year Review)

Dear Ms. Nonvalk:

I am writing to express my strongest support for the pmposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

A huge payment disparity for anesthesia care was created when the RBRVS was instituted, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with dispmportionately high Medicare populations.




Sincerely,

Mary P. Fillinger, MD Associate Professor of Anesthesiology Dartmouth Medical School Dartmouth-Hitchcock Medical Center Lebanon, NH

Page 80 of 547 July 18 2007 03: 19 PM

Submitter : Dr. david jones Date: 07/16/2007

Organization : Anes. Assoc. of Lancaster



Resource-Based PE RVUs

Resource-Based PE R W s

Dear Ms. Nonvalk:

I am writing to express my swongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of ancsthcsia services, and that the Agency is taking steps to address this complicated issue.

When the REiRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work eompared to other physician services. Today, more than a decade since the REiRVS took effect, Medicare payment for anesthesia services stands at just $16.1 9 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step fonvard in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



David E. Jones, M.D.

Page 81 of 547 July 18200703:19PM

Submitter : Dr. Sunita Bbamidipaty Date: 07/16/2007

Organization : Anesthesiology



GENERAL



Dear Ms. Norwalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia senices stands at just % 16.1 9 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in conecting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed mlc, and I support full implementation of the RUC s recommendation.



Page 82 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Lucille Mostello

Organization : Dr. Lucille Mostello



GENERAL

Date: 07/16/2007

GENERAL


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an urnusrainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.




Page 83 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Kim Allen Porterfield

Organization : Dr. Kim Allen Porterfield



GENERAL

GENERAL

See attachment

CMS- 1385-P-2548-Attach-] .DOC

Page 84 of 547

Date: 07/16/2007

July 18 2007 03: 19 PM



Dear Ms. Norwalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation's seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.




Kim A. Porterfield, M.D.

Submitter : Dr. Frederick Payne

Organization : Dr. Frederick Payne

Date: 07/16/2007


Issue Areas/Commenta

GENERAL

GENERAL

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-I 385-P P.O. Box 8018 Baltimore, MD 21 244-801 8

Re: CMS- 1385-P


Dear Ms. Nonvalk:

I am writing to express my strongest support for the pmposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.1 9 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away fmm areas with disproportionately high Medicare populations.


To ensure that our patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia convcrsion factor increase as recommended by the RUC.


Frederick B Payne MD

Page 85 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Rafi Avitsian

Organization : Cleveland Clinic



Date: 07/16/2007

GENERAL

GENERAL Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore. MD 21244-801 8


Dear Ms. Nonvalk:






Page 86 of 547 July 18 2007 03: 19 PM

Submitter : Mr. Robert Luebbers

Organization : Retired, Illinois Dept of Public Health



Date: 07/16/2007

GENERAL

GENERAL

Dear Ms. Nonvalk:

I am writing to express my strongest support for the proposal to increase anesthnia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.1 9 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency acceptd this recommendation in its proposed ~ l e , and I support full implementation of the RUC s recommendation.



Page 87 of 547 July 18200703:19PM

Submitter : Dr. Terence Cone Date: 07/16/2007

Organization : Dr. Terence Cone



Coding- Additional Codes From $Year Review


Dear CMS Folks: My letter is to express the strongest support possible for the proposed increase in anesthesia payments under the 2008 Physician Fee Schedule.

The original RBRVS system disproportionately penalized anesthesiologists (compared to surgeons caring for the same patients), and this has only gotten worse as our population has gotten older, sicker, and more complieated with longer medication lists (which tends to complicate the anesthesia significantly more than the surgery -- the surgery for a 40 year-old and an 80 year-old total hip patient are much the same, but the anesthesia is VERY different).

Anesthesia in the United States has had a 30-fold increase in safety over the past 20+ years, yet we have had larger Medicare cuts than many other specialties that have had very minimal improvements in safety. Anesthesia residencies are longer than ever (now 5 years for many) because of the ever-increasing complexity of our patients.

Having pracrised in both West Virginia and more recently Nevada during the past 5 years, I have noted high and evcr-increasing proportions of Medicare patients, with considerable demographic growth of retirees in both states. With the 8.9% 2006 pay cuts from Medicare, the pay for providing anesthesia care for doing older, sicker, and more complex patients is now down to about 113 of levels paid by private insurance policies for doing similar cases on younger, healthier, and much simpler patients. The result is that we are punishing experienced anesthesiologists who choose practices with a high percentage of Medicare patients. In order to pay increasing overhead, living expenses, and malpractice insurance costs, anesthesiologists are being forced toward practices that serve fewer Medicare patients, leaving significant numbers of very sick Medicare patients with less-experienced anesthesia providers. Certain anesthesiologists who serve particular surgeons (such as those who do large numbers ofpatients for total joint replacements or other geriatric-centered procedures) are penalized tens of thousands of dollars annually just by having a practice that is 213 Medicare, and the financial penalty is even worse if the anesthesiologist spends the extra time and attention that these retirees really deserve. Of course there are non-monetary rewards for serving America's retirees, but it is difficult to pay one's insurance premiums with these intangible benefits.

In any case, no matter how you look at it -- whether from a practical approach, a work-based approach, an education-based concept, or just what is 'fair' for both patient and anesthesiologist -- a $4.00 increase per anesthesia unit would go a long way toward fixing the problem, even though that will still leave Medicare paying less than half the rate of many private insurers.

Thank you for your attention and consideration toward reducing the current 'penalty' that Medicare gives to anesthesiologists who care for large numbers of Medicare patients.

Sincerely, Terence M. Cone, 24 13 Rancho Be1 Air Dr Las Vegas NV 89 107

Page 88 of 547 July 18200703:19PM

Submitter : Dr. Brian Owens

Organization : Virginia Mason Medical Center



Date: 07/16/2007

GENERAL

GENERAL Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS- 1385-P P.O. Box 80 18 Baltimore. MD 21244-80 18


Dear Ms. Nonvalk:






Page 89 of 547 July 18200703:19PM

Submitter : Dr. John Savarese

Organization : Weill Cornell Medical College


Date: 07/16/2007


GENERAL

GENERAL

July 16,2007



Dear Ms. Nonvalk:



In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor fo offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



John J. Savarese, M.D. Professor and Chairman Department of Anesthesiology Weill Cornell Medical College

Page 90 of 547 July 18 2007 03: 19 PM

Submitter : Date: 07/16/2007

Organization :



Resource-Based PE RVUs

Resource-Based PE R W s

Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore, MD 2 1244-801 8


Dear Ms. Norwalk:






Paul J. Christo, MD, MBA Assistant Professor Johns Hopkins Medicine Baltimore, MD 2 1205

Page 91 of 547 July 18200703:19PM

Submitter : Joseph Seltzer

Organization : Jefferson Medical College


Date: 07/16/2007


GENERAL

GENERAL

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 801 8 Baltimore, MD 2 1244-801 8

Re: CMS- 1385-P Anesthesia Coding (Part of 5-Year Revicw)

Dear Ms. Nonvalk:

I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. 1 am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.


In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of neady $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.

To ensure that our patients have access to cxpert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Page 92 of 547 July 18 2007 03: 19 PM

Submitter :

Organization : Jeferson Anesthesiology Assoicates



Date: 07/16/2007

GENERAL

GENERAL Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 801 8 Baltimore, MD 2 1244-801 8

Re: CMS-1385-P


Dear Ms. Nonvalk:


When the RBRVS was instituted, it created a huge paymcnt disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to othcr physician services. Today, more than a decade since the RBRVS took effec< Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s senioa, and is creating an unsustainable system in which anesthesiologists are W i g forced away from areas with disproportionately high Medicare populations.


To ensure that our patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia eonversion factor increase as recommended by the RUC.


Page 93 of 547 July 18200703:19PM

Submitter : Dr. David Peng

Organization : William Beaumont Hospital



Date: 07/16/2007



Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS- 1385-P P.O. Box 8018 Baltimore, MD 2 1244-801 8

Re: CMS- 1385-P


Dear Ms. Norwalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s senion, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in w m t i n g the long-standing undervaluation of anesthesia services. 1 am pleased that the Agency accepted this recommendation in its proposed mle, and I support full implementation of the RUC s recommendation.



Page 94 of 547 July 18 2007 03:19 PM

Submitter : Dr. Ryan Nagy

Organization : Dr. Ryan Nagy


Date: 07/16/2007

Issue AreasJComments

GENERAL

GENERAL Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS- 1385-P P.O. Box 801 8 Baltimore, MD 2 1244-801 8

Re: CMS-1385-P


Dear Ms. Norwalk:


When the RBRVS was instituted, it created a hugc payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move h a t would result in an increase of neady $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. 1 am pleased that the Agency accepted this recommendation in its proposed ~ l e , and I support full implementation of the W C s recommendation.

To ensure that our patients have access to expert anesthesiology medical care, it is impcrative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Page 95 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Megan Paskitti

Organization : Dr. Megan Paskitti



Date: 0711612007

GENERAL

GENERAL

Desr Ms. Norwalk:



In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an incmse of nearly $4.00 per anesthesia unit and serve as a major step forward in conecting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed mle, and I support full implementation of the RUC s recommendation.



Page 96 of 547 July 18200703:19PM

Submitter : Dr. Jennifer Clark

Organization : Columbia Orthopaedic Group



Date: 0711612007

GENERAL

GENERAL Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 801 8 Baltimore, MD 2 1244-8018

Re: CMS- 1385-P


Dear Ms. Nonvalk:

I am writing to express my strongest suppon for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.1 9 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.



In addition, as our population ages they now have more comorbidities and more serious problems than ever. Due to cost, the hospitals use the cheapest labor available which is also less skilled. This only compounds the problem and adds to our senior citizens and disabled populations receiving lesser care than their younger and more able bodied counterparts.


Jennifer LK Clark MD FAAPMR

Page 97 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Michael Feren

Organization : Anesthesia Services Medical Group



Date: 07/16/2007

GENERAL

GENERAL Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS- 1385-P P.O. Box 8018 Baltimore, MD 2 1244-801 8


Dear Ms. Norwalk:



In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s nxommendation.



Page 98 of 547 July 18 2007 03:19 PM

Submitter : Dr. Michael Moellenhoff

Organization : ASMG



Date: 07/16/2007

Geographic Practice Cost Indices (GPCIs)

Geographic Practice Cost Indices (GPCIs)


Re: CMS-1385-P Anesthesia Coding (Patt of 5-Year Review)

Dear Ms. Nonvalk:

I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the goss undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.


In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and 1 support full implementation of the RUC s recommendation.

To ensure that our patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor inerease as recommended by the RUC.

In addition, I would like to suggest that San Diego County's geographic rates be increased to a level which more closely approaches the high cost of living here to a level similar to Los Angeles and the Bay Area of Northern California.


CMS-I 385-P-2563-Attach-1 .DOC

Page 99 of 547 July 18200703:19PM



Dear Ms. Norwalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.1 9 per unit. This amount does not cover the cost of caring for ow nation's seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.



In addition, I would like to suggest that San Diego County's geographic rates be increased to a level which more closely approaches the high cost of living here to a level similar to Los Angeles and the Bay Area of Northern California.


Sincerely, Michael Moellenhoff, MD Sharp Memorial Hospital San Diego San Diego, CA 92 1 09

Submitter :

Organization :

Date: 07/16/2007



GENERAL

GENERAL



In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in comting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Page 100 of 547 July 18200703:19PM

Submitter : Dr. David Chestnut

Organization : Gundersen Lutheran



Date: 07/16/2007



I am writing re: CMS-1385-P, with regard to anesthesia coding.

I am writing to express my support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instituted, it created apayment disparity for anesthesia care, mostly due to undervaluation of anesthesia work compared to other physician servies. Today, Medicare payment for anesthesia services is only $ 16.19 per unit. This aniount does not cover the cost of caring for our nation's seniors and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this situation, thc RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32% work undervaluation -- which would be a major step forward in correcting the long-standing undervaluation of ancsthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implemantation of the RUC's recommendation.


Page 101 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Steven Maves

Organization : Dr. Steven Maves



GENERAL

GENERAL Docket CMS-1385-P. I sh.0ngly support the feel adjustments for anesthesia provide in CMS-1385-P.

Page 102 of 547

Date: 07/16/2007

July 18 2007 03: 19 PM

Submitter : Dr. Melissa Anglin

Organization : Dr. Melissa Anglin



Date: 07/16/2007

GENERAL

GENERAL Please help physicians provide care for Medicare patients by increasing fee payments for treatment of such patients. As I am sure you are aware that with increasing liability insurance premiums and other increasing costs, it can become cost prohibative to care for Medicare patients. Please help to protect them by paying physicians a fairer payment for services rendered.

Page 103 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Kevin Klimek

Organization : Anesthesia Associates of Ann Arbor


Issue Arees/Comments

GENERAL

GENERAL

See Attachment

Page 104 of 547

Date: 07/16/2007

July 18 2007 03: 19 PM



Dear Ms. Norwalk:


When the Rl3RVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the Rl3RVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation's seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.




Kevin E. Klimek, MD Anesthesia Associates of Ann Arbor 2006 Hogback Rd. Suite 5 Ann Arbor, MI 48 106

Submitter :

Organization : Anesthesia Consultants of California Medical Group



Date: 07/16/2007

GENERAL

GENERAL


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not wver the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forwad in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Page 105 of 547 July 18200703:19PM

Submitter : Dr. Chiedozie Udeh Date: 07/16/2007

Organization : Dr. Chiedozie Udeh



GENERAL

GENERAL

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore, MD 21244-801 8


Dear Ms. Nonvalk:

I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I would also like to express my appreciation that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instituted, it unfortunately created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not wver the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommcnded that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in wnecting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.

To ensure that our patients have access to expert anesthesiology medical care, it is important that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Sincerely Chiedozie Udeh MBBS

Page 106 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Mark Margolis Date: 07/16/2007

Organization : Metropolitan Anesthesia Consultants



GENERAL

GENERAL

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medieaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore, MD 21244-8018


Dear Ms. Nonvalk:

I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Ageney is taking steps to address this complicated issue.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologisw are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work UIIde~aluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Page 107 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Douglas Stewart Date: 07/16/2007

Organization : Dr. Douglas Stewart



GENERAL

GENERAL Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore, MD 21244-8018


Dear Ms. Nonvalk:



In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia eonversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of neady $4.00 per anesthesia unit and serve as a major step forward in comting the long-standing undervaluation of anesthesia services. I am pleased that the Agency aecepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.


Thank you for your consideration of this serious matter. Douglas P Stewart MD

Page 108 of 547 July 18200703:19PM

Submitter : Dr. Lois Stoltze

Organization : McFarland Clinic, Ames, Iowa



Date: 07/16/2007

GENERAL

GENERAL

I want to support CMS 1385-P which would increase the anesthesia conversion factor. The reimbursement for medicare patients is so low it makes it difficult to cover costs. Ow vascular surgeon left the clinic due to the unfavorable medicare/insurance payment ratio (much higher number of medicare patients with poor reimbursement). Without relief, we, too, might need to discontinue or severely limit the number of medicare cases that we do. Thank you for consideration of this measure.

Page 109 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Tina Jobe

Organization : Magnolia Anesthesiology Associates



GENERAL

Date: 07/16/2007

GENERAL

Leslie V. Norwalk, Esq.



Attention: CMS- 1385-P

P.O. Box 801 8

Baltimore, MD 2 1244-801 8

Re: CMS-1385-P


Dear Ms. Norwalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are beiig forced away from areas with disproportionately high Medicare populations.



Thank you for yow consideration of this serious matter.

Tina M. Jobe M.D.

Page 1 10 of 547 July 18200703:19PM

Submitter : Dr. Ann Kiesau Date: 07/16/2007

Organization : University of Arizona



GENERAL

GENERAL

Dear Ms. Norwalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Mcdicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away fmm areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency aceepted this recommendation in its proposed mle, and I support full implementation of the RUC s recommendation.

To ensure that our patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia eonversion factor increase as recommended by the RUC.


Dr. Ann Kiesau University of Arizona Anesthesiology

Page 1 1 1 of 547 July 18 2007 03: 19 PM

Submitter : Mr. John Stark Date: 07/16/2007

Organization : University of Iowa Anesthesia



GENERAL

GENERAL

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 801 8 Baltimore, MD 2 1244-801 8


Dear Ms. Nonvalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not wver the cost of caring for our nation s seniors, and is creating an umustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC reeommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step fonvard in w m t i n g the Long-standing undervaluation of anesthesia services. I am pleased that the Ageney accepted this recommendation in its proposed rule, and I support full implementation of the RUC s rewmmendation.



Page 1 12 of 547 July 18 2007 03:19 PM

Submitter : Dr. Raymond Andrews

Organization : Medical Anethesiolgy Associates



Date: 07/16/2007

GENERAL

GENERAL


Re: CMS-1385-P


Dear Ms. Nonvalk:



In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of neady $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed mle, and I support full implementation of the RUC s recommendation.



Page 113 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Peter Motolenich

Organization : Bel-Park Anesthesia Associates



Date: 07/16/2007

GENERAL

GENERAL



Dear Ms. Nonvalk:



In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. 1 am pleased that the Agency aeeepted this rccomrnendation in its proposed rule, and I support full implementation of the RUC s recommendation.

To ensure that our patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia eonversion faetor inerease as recommended by the RUC.


Pete Motolenich. MD

Page 114 of 547 July 18200703:19PM

Submitter : Mr. T. Call

Organization : Mr. T. Call

Category : Health Care Professional or Association

Date: 07/16/2007


GENERAL

GENERAL

Leslie V. Nowalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore, MD 2 1244-80 18

Re: CMS-1385-P


Dear Ms. Nowalk:

I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking stcps to address this complicated issue. As a medical student who has devoted much time, energy and money to becoming a physician, it is promising to see that the services that I will provide to my

community are valued by CMS. Thanks, T.R. Call

Page 11 5 of 547 July 18 2007 03:19 PM

Submitter : Dr. Adam Schow

Organization : Anesthesia Associates of Kansas City



Date: 07/16/2007

GENERAL

GENERAL

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS- 1385-P P.O. Box 8018 Baltimore, MD 2 1244-801 8

Re: CMS-1385-P


Dear Ms. Nonvalk:

I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to addrcss this complicated issue.

When the RI3RVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RI3RVS took effect, Medicare payment for anesthesia services stands at just $1 6.1 9 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of neady $4.00 per anesthesia unit and serve as a major step fonvard in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Adam Schow. MD

Page 1 16 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Ralph Nussbaurn

Organization : Texas Tech University


Date: 07/16/2007

Issue AreaslCornrnents

GENERAL

GENERAL


Re: CMS-1385-P


Dear Ms. Nonvalk:

Attached is a letter the contents of which are well worded. My addition to this is that as an academic anesthesiologist this increase is a beginning shich will cnable the continuation of education of anesthesia services. The private sector has carved out a disproportinatly higher reimbursement population of patients which cripples our ability to maintain even basic staffing. This results in inferior quality of education. It is imperative that medicare rates be adjusted. 1 go further than an across the board adjustment and recommend a unique adjustment to provide for quality staff that can maintain quality education.

Thank you

Ralph Nussbaum, DO Texas Tech University Department of Anesthesiology

1 am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. 1 am gratehl that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.


In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support h l l implementation of the RUC s recommendation.

To ensure that our patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by hlly and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Page 1 17 of 547 July 18 2007 03: 19 PM

Submitter : Dr. james griffeth

Organization : Dr. james griffeth



Date: 07/16/2007

GENERAL



Dear Ms. Nonvalk:


When thc RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations. Medieare patients comprise almoost 50% of our patient population. We practice in an area recently hit hard by jobs going overseas and many of our young patients are under or uninsured.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step fonvard in correcting the long-standing undervaluation of anesthesia serviees. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Sincerely, Jim Griffeth M.D.

Page 1 18 o f 547 July 18 2007 03: 19 PM

Submitter : Dr. Anne Hackett

Organization : WVU


Issue Areas/Commeots

Date: 07/16/2007

GENERAL

GENERAL

1 strongly support the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. 1 am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to correct this situation.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services in West Virginia where 1 practice stand at just $16.60 p e ~ unit. This amount does not cover the cost of caring for our patients, and is creating an unsustainable system in which anesthesiologists must limit the number of Medicare patients we treat.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation-a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. T am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.

To ensure that our patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.

Thank you for your considcration of this serious matter.

Page 1 19 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Amber Stein Date: 07/16/2007

Organizntion : Commonwealth Anesthesia Associates



Payment For Procedures And Services Provided In ASCs




Dear Ms. Nonvalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, morc than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just 316.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.




Sincerely, Amber L. Stein, M.D. Richmond. VA

Page 120 of 547 July 18 2007 03: 19 PM

Submitter : Jay Epstein

Organization : Jay Epstein


Date: 07/16/2007


GENERAL

GENERAL


Dear Ms. Norwalk:






Jay Epstein, MD

Page 12 1 of 547 July 1 8 2007 03: 1 9 PM

Submitter : Dr. Edward Seugling Date: 07/16/2007

Organization : Christiana Care Health SystemIASPA


GENERAL

GENERAL



Dear Ms. Nonvalk:



In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in wnecting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.

To ensure that o w patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the FederaI Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Sincerely,

Edward M. Seugling, MD Anesthesiologist Christiana Care Health System Newark, Delaware Email: [email protected]

Page 122 of 547 July 18200703:19PM

Submitter : Dr. Steven Outly

Organization : Rush University Medical Ctr


Issue Areas/Commenb

Date: 07/16/2007



Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore, MD 21244-801 8


Dear Ms. Norwalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care. mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation's seniors, and is crating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of neady $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. 1 am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC's rccommendation.



Sincerely yours, Steven Outly, M.D.

Page 123 of 547 July 18200703:19PM

Submitter : Dr. Richard Ropp

Organization : Rush University Med Ctr


Date: 07/16/2007





Dear Ms. Norwalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $ 16.19 per unit. This amount does not cover the cost of caring for our nation's seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation - a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC's recommendation.

To ensure that o w patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.

Thank you for yow consideration of this serious matter.

Sincerely, Richard Ropp, M.D.

Page 124 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Christopher Swide

Organization : Dr. Christopher Swide



Date: 07/16/2007

GENERAL

GENERAL Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS- 1385-P P.O. Box 8018 Baltimore, MD 21 244-801 8


Dear Ms. Nonvalk:




To ensure that our patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Registcr by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Christopher Swide, MD

Page 125 of 547 July 18 2007 03:19 PM

Submitter : Dr. Merete Ibsen Date: 07/16/2007

Organization : UIHC-Anesthesia



GENERAL

GENERAL

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medieare and Medicaid Services Attention: CMS- 1385-P P.O. Box 801 8 Baltimore, MD 2 1244-80 18


Dear Ms. Nonvalk:

I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. 1 am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just 1616.1 9 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and 1 support full implementation of the RUC s recommendation.



Dr. Merete Ibsen, M.D. Assistant Professor UIHC-Anesthesia 200 Hawkins Drive Iowa City, 1A 52242

Page 126 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Alla Druker

Organization : Manassas Anesthesia Associates, P.C.



Date: 07/16/2007

GENERAL

GENERAL Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS- 1385-P P.O. Box 801 8 Baltimore. MD 2 1244-801 8


Dear Ms. Nonvalk:



In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of neally $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am plcased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.

To ensure that our patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with thc proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Alla Druker, M.D.

Page 127 of 547 July 18 2007 03:19 PM

Submitter : Dr. Paul Collins

Organization : University of North Carolina School of Medicine



Date: 07/16/2007

GENERAL

GENERAL Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimore, MD 2 1244-8018

Re: CMS-1385-P


Dear Ms. Nonvalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being f o r d away from areas with disproportionately high Medicare populations.




Page 128 of 547 July 18 2007 03:19 PM

Submitter : Dr. Timothy Cahill

Organization : Anesthesia Associates of Ann Arbor


Date: 07/16/2007


GENERAL

GENERAL


Re: CMS-1385-P

Anesthesia Coding (Part of 5-Ycar Review)

Dear Ms. Norwalk:

I am writing to express my strongest support for the proposal to increase anesthesia payments undcr the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instihlted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being f o d away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation,

To ensurc that our patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Page 129 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Christopher Lampson Date: 07/16/2007

Organization : Dr. Christopher Lampson



GENERAL



Dear Ms. Nonvalk:





Christopher Lampson, D.O. Doctors Hospital, Ohio Health 5100 West Broad Steet Columbus, Ohio 43228

Page 130 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Paul Collins

Organization : University of North Carolina School of Medicine


Date: 07/16/2007


GENERAL

GENERAL


Re: CMS-1385-P


Dear Ms. Norwalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just 5 16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of neariy $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Page 13 1 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Robert Harris Date: 07/16/2007






Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 801 8 Baltimore, MD 2 1 244-80 18

Re: CMS-1385-P Anesthesia Coding (Part of 5-Year Rcview)

Dear Ms. Norwalk:

I am writing to express my st~ongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not wver the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. 1 am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Page 132 of 547 July 18 2007 03:19 PM

Submitter : Dr. sandeep khanna

Organization : anesthesia semce medical group



Date: 07/16/2007





Dear Ms. Nonvalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade sincc the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsusrainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.




Page 133 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Paula Roos

Organization : Billings Anesthesiology, P.C.



Date: 07/16/2007

GENERAL

GENERAL

I support the proposed increase in payment for anesthesia services. It is clear that access to physicians for Medicare patients will otherwise be at risk. Please assure continued access for these patients by following through with the increased payments.

Page 134 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Ruth Winter

Organization : Dr. Ruth Winter



Date: 07/16/2007

GENERAL

GENERAL


Re: CMS- 1385-P


Dear Ms. Nonvalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the cost of caring for our nations seniors, and is creating an unsustainable system in which anesthesiologists are being f o n d away from areas with disproportionately high Medicare populations.




Ruth R. Winter, M.D.

Page 135 of 547 July 18 2007 03:19 PM

Submitter : Dr. Karl Talts

Organization : Dr. Karl Talts



Date: 07/16/2007

GENERAL

GENERAL Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 801 8 Baltimore. MD 2 1244-80 18

Re: CMS-1385-P


Dear Ms. Norwalk:



In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia serviccs. 1 am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Page 136 of 547 July 18 2007 03: 19 PM

Submitter : Nikki Jaworski

Organization : OHSU


Date: 07/16/2007


GENERAL

GENERAL



Dear Ms. Norwalk:

I am writing to express my strongest support for thc proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.1 9 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an uwustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC rccommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Page 137 of 547 July 18 2007 03: 19 PM

Submitter : Dr. Melissa Kokoszka

Organization : Dr. Melissa Kokoszka



Date: 07/16/2007

GENERAL


Re: CMS-1385-P


Dear Ms. Nonvalk:

I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am gratefuI that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.


In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step fonvani in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.

To ensure that our patients have access to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and imrncdiately implementing the anesthesia conversion factor increase as recommended by the RUC.


Melissa J. Kokoszka, MD

Page 138 of 547 July 18 2007 03: I9 PM

Submitter : Dr. Adnan Khan Date: 07/16/2007



GENERAL

GENERAL Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS- 1385-P P.O. Box 8018 Baltimore, MD 2 1244-80 18


Dear Ms. Nonvalk:

I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized the goss undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.


In an effort to rectify this untenable sihlation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Ageney accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Page 139 of 547 July I8 2007 03: 19 PM

Submitter : Dr. Stuart Leaderman

Organization : Dr. Stuart Leaderman

Category : Other Health Care Professional

Date: 07/16/2007


GENERAL

GENERAL

To Whom it may concern,

I am writing to express my sh-ongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am gratell that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just 516.19 per unit. This amount does not cover the cost of caring for our nation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an.effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Sincerely,

Stuart Leaderman D.O.

Page 140 of 547 July 18200703:19PM

Submitter : Dr. Richard Heyendal

Organization : California Anesthesia Associates


Issue AreaslCornments

GENERAL

GENERAL

See Anachment

Page 141 of 547

Date: 07/16/2007

July 18 2007 03: 19 PM

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