Submitter Dr. Candace Metcalf Date: 07/25/2007 Organization … · 2019. 9. 12. · Submitter : Dr....

Submitter : Dr. Candace Metcalf

Organization : Dr. Candace Metcalf

Category : Physician

Issue Areas/Comments

Date: 07/25/2007

GENERAL

GENERAL

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

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

Dear Ms. Norwalk:

I am writing to express my stxongest support for the proposal to inerease 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 to offset a calculated 32 pereent 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 aeeepted 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 eare, 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.

Candace Metcalf, D.O.

94 of 908 August 01 2007 1 1:33AM

Submitter : Dr. Donald Martin Date: 07/25/2007

Organization : American Society of Anesthesiologists



Coding-- Additional Codes From 5-Y ear Review

Coding-- Additional Codes From 5-Year Review

Leslie V. Nonvalk, Esq. Aeting Administrator Ccnters for Mcdicare and Medicaid Services Awntion: CMS- 1385-P P.O. Box 8018 Baltimore, MD 2 1244-8018 Re: CMS-1385-P

Ancsthesia Coding (Part of 5-Year Review)

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 thc 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 which occurred in part because: I) anesthesia services remain 'time based' and so are difficult to compare directly with most other procedural services, and 2) The anesthesia services used as 'crosswalks', to compare with services in other specialties, happened to be some of the lowest values services provided by our specialty. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $1 6.19 per unit. This amount is currently less than 38% of the amount actually paid by the largest private payers in the state of Pennsylvania! Further, this amount does not covcr 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 dispmportionatcly 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 our patients have access to cxpcn medical care from specialist anesthesiologists, it is imperative that CMS approve the proposal in the Federal Registcr by fully and immediately implement the anesthesia conversion factor increase as recommended by the RUC.

Thank you for your consideration of this matter which is important in insuring access to surgical and anesthesia services for our nation's seniors.

Page 195 of 908 August 01 2007 11 :33 AM

Submitter : Dr. Jay Tendler, M.D.

Organization : Dr. Jay Tendler, M.D.


Issue AreasIComments

Date: 07/25/2007

Resource-Based PE RVUs

Resource-Based PE R W s

1 have been in practice for 25 years and have felt extremely frustrated that Anesthesiology is such a poorly compensated field by Medicare. My surgical colleagues have been able to care for Medicare patients and not feel financially burdened. This has not been the case for anesthesiologists. For years I have taken care of very ill patients who require the most skill and effort, for unreasonably low reimbursement rates. This issue has been studied under many different methodologies which have consistently demonstrated that anesthesiology is relatively undervalued compared to other medical and surgical specialties. This needs to be corrected---the sooner, the better.

Jay Tendler, MD

Page 196 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. Donna Pearce

Organization : Columbia University- Harlem Hospital Center



GENERAL

GENERAL See Attachment

CMS-I 385-P-4081-Attach-1.m

Page 197 of 908

Date: 07/25/2007

August 01 2007 1 1:33 A M

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 1 8

Re: CMS-1385-P Anesthesia Coding (Part of 5-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 gratefbl 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 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 the anesthesia conversion factor increase as recommended by the RUC.


Submitter : Dr. thomas ryan

Organization : summit anesthesiology


Issue AreaslComments

Date: 0712512007

TRHCA-Section 108: CAP

TRHCA--Section 108: CAP 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 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 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.

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 incrcase as recommended by the RUC.


Sincerely, Thomas J. Ryan, M.D.

Page 198 of 908 August 01 2007 11:33 A M

Submitter : Christopher Gharibo

Organization : NYU Medical Center



Date: 07/25/2007

Ambulance Services

Ambulance Services

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 Ancsthcsia Coding (Part of 5-Year Review)

Dear Ms. Norwalk:

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 thc gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue. .

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 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 effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offsct 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.


Thank you for your eonsideration of this serious matter.

Page 199 of 908 , August 01 2007 11:33 AM

Submitter : Dr. Herbert Luo

Organization : Associated Anesthesiologists, SC



Date: 07/25/2007

Coding- Additional Codes From 5-Y ear Review


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

Re: CMS-1385-P Anesthesia Coding (Pan 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. 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.

Whcn 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 $16.1 9 per unit. This amount does not cover the cost of caring for ournation s seniors, and is creating an unsustainable system in which anesthesiologists are being forced away from arcas with disproportionately high Medicare populations.

In an cffort to rcctify 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 undcrvaluation of anesthesia services. I am pleased that the Agency acceptcd this recommendation in its proposed rule, and I support fill implementation of the RUC s recommendation.

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 fi~lly and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Herben Luo. MD

Page 200 of 908 August 01 2007 11:33 AM

Submitter : Dr. Oscar Zagala

Organization : Good Samaritan Hospital


Issue Areastcomments

Date: 07/25/2007

GENERAL

GENERAL Leslie V. Norwalk, Esq. Acting Administrator Centcn 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 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 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 increasc 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 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 thc anesthesia conversion factor incrcase as recommended by the RUC.


Sinccrcly,

Dr. Oscar Zagala Ancsthesiologist

Page 201 of 908 August 01 2007 11:33 AM

Submitter : Dr. Daniel LaValley Date: 07/25/2007

Organization : Duke University Dept. of Anesthesiology



Background

Background

Leslie V. Norwalk, 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 (Pan of 5-Year Review) Dear Ms. Norwalk: I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physieian Fee Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia serviccs, 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 $16.19 per unit. This amount does not cover the cost of caring for our nations seniors, and is creating anunsustainable 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 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 incrcasc as recommended by the RUC.

Page 202 of 908 August 01 2007 11:33 AM

Submitter : Mrs. Freda Harper Date: 07/25/2007

Organization : Mrs. Freda Harper

Category : Individual


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

Re: CMS-1385-P Anesthesia Coding (Pm 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 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 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 expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthcsia conversion factor increase as recommended by the RUC.


Page 203 of 908 August 01 2007 11:33 AM

Submitter : Dr. Timothy Pastore Date: 07/25/2007

Organization : Dr. Timothy Pastore



GENERAL

GENERAL

I am an ancsthesiologist in Pennsylvania. Our specialty has been exceptionally hard hit by the reductions in the anesthesia work rules and conversion factor by Medicare over the last 20 years. As of now, the Medicare conversion factor for anesth. services is less than 30% of all other third party payors. In Penna. this hits us even harder as we have a comparitively large elderly population. We are unable to recruit young anethesiologists as a result and thus we are faced with burning ourselves out or relocating to areas with younger populations. This is already occuring and eventually will result in great disruptions in access to care for the elderly. Please consider favorably the proposal to increase the anethesia conversion factor.

Sincerely, Timithy Pastore, MD

Page 204 of 908 August 01 2007 1 1 :33 AM

Submitter : Mrs. Dora Halford

Organization : Mrs. Dora Halford



GENERAL

GENERAL

See Attachment

CMS- 1385-P-4089-Attach-I .DOC

Date: 07/25/2007

Page 205 of 908 August 0 1 2007 1 1 :33 AM

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 1 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 $1 6.19 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 1 support full implementation of the RUC's recommendation.


Thank you for your consideration of this serious matter

Submitter : Date: 07/25/2007

Organization :



GENERAL

GENERAL

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


Dear Ms. Norwalk:

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.

Whcn the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work comparcd 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 perccnt 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 implemcntation of the RUC s recommendation.



Page 206 of 908 August 01 2007 11:33 AM

Submitter : Mr. James Rott Date: 07/25/2007

Organizntion : Mr. James Rott

Category : Other Health Care Professional


Therapy Standards and Requirements

Therapy Standards and Requirements

As a Physical Therapist Assistant who has been adversely effected by the interpretation of regulation CFR484.4.1 was dissapointed to see in the new preposed reguyation that you have done nothing to change the regulation so that those of us who have qualified by equivelency to take and have passed the board exams in California are still techincally not eligible to provide services to Medicare patients. I have been licensed by the State of California for 17 years now and find it appaling that the proposed regulation for those who started their practice before Jan 1, 2008 reads the same as it did before. The statement in the regulation in part ii for those starting their practice before Jan 1,2008 that reads "except that these determinations of proficiency do not apply with respect to persons initially licensed by a state or seeking initial qualification as a physical therapist assistant after December 31, 1977" needs to be stricken so that the roughly 2000 of us who qualified by equivelency to take the boards in California and passed can continue to provide the high quality of care to Medicare patients like we were before. By not changing the regulation it is not only illegal to essentially de-license us but also is reducing the amount of providers available to treat Medicare patients and thcrefore reducing the quality of care available for these patients and increasing the cost of healthcare. It is also very frustrating to myself and everyone else effectcd to have worked hard to write everyone imaginable to hy and change this illegal interpetation and to be told that the regulation was being re-written to see taxpayers money wasted on essentially nothing being done. I'm swe that if we all banded together and fought this the court system would agree and find in ow favor. When did the fcderal government decide to control the licensing standards of the states? Please change this unfair and illegal interpretation of the regulation so that wc can get back to providing the high quality of care to Medicare patients and keep the cost of healthcare affordable. Thank you for your time.

Page 207 of 908 August 01 2007 1 1:33 AM

Submitter : Dennis Crane

Organization : Dennis Crane



GENERAL

Date: 07/26/2007

GENERAL

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. 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 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 unsusainable system in which anesthesiologists are being forced away fmm arcas 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 cormcting 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.



Dennis Crane, DO Yakima, WA

Page 209 of 908 August 01 2007 1 1 :33 AM

Submitter : Dr. Robert Wbitcomb

Organization : Elmhurst Anesthesiologists



GENERAL

Date: 0712612007

GENERAL

Sec attachment

CMS- 1385-P-4094-Attach-] .DOC

CMS- 1385-P-4094-Attach-2.DOC

CMS-1385-P-4094-Attach-3.DOC

Page 2 10 of 908 August 01 2007 11:33 AM



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.

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.


Submitter :

Organization :


Date: 07/26/2007


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 2 1244-8018

Re: CMS-1385-P


Dcar 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 thc 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.

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 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.


Regards, Christopher Collison, M.D.

Page 2 1 1 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. Kevin Tarrant

Organization : Oregon anesthesiology group



Date: 07/26/2007

Coding- Additional Codes From 5-Year Review



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 unsusrainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an effort to rcctify this untenable situation, the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work un&rvaluation a move that would msult 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 recornmendation in its proposed rule, and I support full implementation of the RUC s recommedation.



2 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. Matthew Hoopes

Organization : Dr. Matthew Hoopes



Date: 07/26/2007

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


Dcar Ms. Nonvalk:

I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fec Schedule. I am gratcful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking stcps 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 othcr physician services. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 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 disproponionately 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 undcrvaluation 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 FedcraI Register by fully and immediately implementing the anesthesia conversion factor inerease as recommended by the RUC.

Thank you for your consideration of this serious matter. Thank you for speaking to us at the ASA Legislative Conference in May, 1 found it very informative and enjoyed your presentation.

Sincerely,

Matthew W. Hoopes, M.D.

Page 2 13 of 908 August 01 2007 1 1 :33 AM

Submitter : Dr. Gregory Miller

Organization : Physician Anesthesia Group



GENERAL

GENERAL

see attachment

CMS-I 385-P-4098-Attach-] .PDF

Page 2 14 of 908

Date: 07/26/2007

August 01 2007 1 1 :33 AM

Leslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 80 1 8 Baltimore, MD 2 1244-80 1 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. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit.

Medicare payment has not kept pace with our forms of reimbursement. The unit value is currently lower than it was 25 years ago. Because the dollar had considerably more purchasing power in 1982, this amounts to serious erosion in compensation.

Our anesthesia practice is typical of many groups. Medicare accounts for 40% of our time and effort, yet generates only 12% of our collections. I have yet to meet the person who would turn down giving up 12% of their pay in exchange for an additional 2 1 weeks of vacation. Medicare payments are reaching the point where "walking away", i.e. ceasing participation, will become less and less painful decision. The RUC recommendation to increase the anesthesia unit by almost $4.00 increase will correct some of the undervaluation.

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,

Gregory Miller

Submitter : Dr. Sean Dobson Date: 07/26/2007

Organization : Duke University Health System



GENERAL

GENERAL

Leslie V. Nonvalk, Esq. Acting Administratdr Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 801 8 Baltimorc, 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 proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized thc gross undervaluation of anesthesia scrviccs, 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 to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.00 per anesthcsia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthesia serviccs. 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 paticnts have acccss to expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Fcderal Register by fully and immcdiately implementing the anesthesia conversion factor increase as recommended by thc RUC.

Page 21 5 of 908 August 01 2007 11:33 AM

Submitter : Dr. Timothy Gilbert

Organization : University of Maryland School of Medicine



Date: 07/26/2007

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

Re: CMS-1385-P

Ancsthesia Coding (Part of 5-Year Rcview)

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 thc 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 undcrvaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of thc RUC s recommendation.

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


Timothy B Gilbert, MD, MBA, MSc

Page 216 of 908 August 01 2007 11:33 AM

Submitter : Dr. Tim Adams Date: 07/26/2007

Organization : Dr. Tim Adams



GENERAL

, GENERAL

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

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

Dear Ms. Nonvalk:

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.


In an effort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesiaconversion 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. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Page 21 7 of 908 August 01 2007 11:33 AM

Submitter : Dr. Eric Knorr Date: 07/26/2007

Organization : Dr. Eric Knorr



GENERAL

GENERAL

3 10 W Glenview Dr Salisbury. NC 28 147 July 26,2007



Dear Ms. Norwalk:

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 rccognizcd 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 anesthcsia work compared to other physician services. Today, more than a decade since the RBRVS took effecc 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 cteating 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 Agcncy accepted this recommendation in its proposed rulc, and I support full implementation of the RUC s recommendation.

To cnsure 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.


Sincerely, Eric J. Knorr, MD Salisbury, NC

Page 21 8 of 908 August 01 2007 1 1 :33 AM

Submitter : Dr. BARBARA LEIGHTON

Orgnnhtion : WASHINGTON UNIVERSITY IN SAINT LOUIS



Date: 07/26/2007




Rc: CMS- 1385-P Anesthesia Coding (Part of 5-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 rccognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

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 $16.1 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 arcas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC recommended that CMS increase the ancsthesia 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.



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

Rc: CMS-1385-P Ancsthesia Coding (Part of 5-Year Review)

Dcar 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 gratcful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

Whcn 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 $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 reeommendation in its proposed rule, and I support full implementation of the RUC s recommendation.

Page219of908 August 01 2007 11:33 AM



Page 220 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. Gregory Erb

Organization : Midwest Anesthesia Assoc

Category : Pby sician


Date: 07/26/2007

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


Dear Ms. Nonvalk:

I am writing to express my strongest support for the proposaI 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 othcr physician services. Today, morc 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 senion, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an cffort 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.



Gregory Erb, M.D.

Page 22 1 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. Igor Kravchenko

Organization : Dr. lgor Kravchenko



Date: 07/26/2007

GENERAL

GENERAL Lcslie V. Nonvalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 80 18 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 Fec Schedule. I am grateful that CMS has recognized the gross undervaluation of anesthesia services, and that the Agency is taking steps ta address this complicated issue.


In an effort ta 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 our patients have access ta 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 222 of 908 August 01 2007 1 1 :33 AM

Submitter : Dr. Peter B. Sakas Sakas

Organization : Dubuque Anesthesia



GENERAL

GENERAL

Date: 07/26/2007

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

Re: CMS- 1385-P


Dear Ms. Norwalk:

I am writing to cxpress my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has rccognizcd thc gross undervaluation of ancsthesia services, and that thc 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, morc 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 cleating an unsustainable system in which anesthesiologists are being forced away from arcas 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 neaiiy $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undervaluation of anesthcsia scrvices. 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 ancsthesia conversion factor increase as recommended by the RUC.

Thank you for your consideration of this scrious matter.

Dr. Peter B. Sakas

Page 223 of 908 August 01 2007 11 :33 AM

Submitter : Dr. Anthony Gigliobianco

Organization : Northwest anesthesia and Pain



GENERAL

Date: 07/26/2007

GENERAL


Re: CMS-1385-P


Dear Ms. Nonvalk:


When the RElRVS 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 RElRVS 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 wustainable system in which anesthesiologists are being forced away from mas 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.



Page 224 of 908 August 01 2007 11 :33 AM

Submitter : Dr. Billye Gosnell Date: 07/26/2007

Organization : Northwest Anesthesia and Pain



GENERAL

GENERAL

Lcslic V. Norwalk, 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


Dear Ms. Norwalk:

I am writing to express my strongest support for the proposal to inerease anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized thc 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 Medicare populations.

In an cffon 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.


Thank you for your considcration of this serious matter.

Page 225 of 908 August 01 2007 1 1:33 A M

Submitter : Dr. Naushaba Habib




Date: 07/26/2007

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 1244-80 18

Re: CMS-1385-P


Dear Ms. Norwalk:

I am writing to cxpress 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 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.

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 comcting 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.

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

Thank you for your considcration of this serious matter

Page 226 of 908 August 01 2007 1 1:33 AM

Submitter : Mr. Marvin mason

Organization : Mr. Marvin mason



GENERAL

GENERAL

CMS-1385-P Support the proposal to increase anesthesia payments under the 2008 Physician Fee Schcdule

Page 227 of 908

Date: 07/26/2007

August 01 2007 11:33 A M

Submitter : Dr. Joseph Kuang




Date: 07/26/2007

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 1244-80 18

Re: CMS-1385-P


Dear Ms. Nonvalk:

I am writing to cxpress 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 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. 1 am pleased that the Agency accepted this recommendation in its proposed rule, and 1 support full implementation of the RUC s recommendation.



Page 228 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. Ramachan Lahori




Date: 07/26/2007

GENERAL

GENERAL Lcslic V. Norwalk, 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:


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 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 comcting 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 paticnts 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 229 of 908 August 01 2007 11:33 AM

Submitter : Mrs. Deborah Mason

Organization : Mrs. Deborah Mason



GENERAL

GENERAL CMS 1385P 1 support the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule.

Page 230 of 908

Date: 07/26/2007

August 01 2007 1 1:33 AM

Submitter : Dr. KIng Lai



Date: 0712612007


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-I 385-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 serviees, 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, 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 anesthesiologists are being forced away from areas with disproportionately high Medicare populations.




Page 23 1 of 908 August 01 2007 11:33 AM

Submitter : Dr. Larry Lessard




Date: 07/26/2007

GENERAL

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

Re: CMS-1385-P


Dcar Ms. Norwalk:

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



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


Page 232 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. Joseph Liu



issue Areas/Comments

Date: 07/26/2007

GENERAL

GENERAL Leslie V. Nowalk, 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


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 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 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 thc proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increasc as recommended by the RUC.


Page 233 of 908 August 01 2007 11:33 AM

Submitter : Dr. John Longwell Date: 07/26/2007




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 (Part of 5-Ycar 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 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 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.

To enswe that ow 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.

Thank you for yow consideration of this serious matter.

Page 234 of 908 August 01 2007 1 1 :33 AM

Submitter : Dr. Bing Lu




Date: 07/26/2007

GENERAL

GENERAL

Lcslic V. Nonvalk, 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:

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 anesthesiologists are being forced away ftom areas with disproportionately high Medicare populations.

In an effort to rectifv 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 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 cnsurc 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 235 of 908 August 01 2007 11:33 AM

Submitter : Dr. Alexis Lynley

Organization : Northwest Anestbesia and Pain



Date: 07/26/2007

GENERAL

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

Re: CMS-1385-P


Dcar Ms. Norwalk:

I am writing to cxpress my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has rccognized 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 duc 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 aecepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.

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


Page 236 of 908 August 01 2007 1 1 :33 AM

Submitter : Dr. Benjamin Deratzou

Organization : Dr. Benjamin Deratzou



GENERAL

GENERAL

see attachment

CMS-I 385-P-4120-Attach-2.TXT

Page 237 of 908

Date: 07/26/2007

August 01 2007 1 1 :33 AM

Leslie V. Norwalk, 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


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.



Submitter : Dr. Michelle McLellan



lssue AreasIComments

Date: 07/26/2007

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

Ancsthcsia Coding (Part of 5-Year Review)

Dcar Ms. Nonvalk:

I am writing to cxpress my strongest support for thc proposal to increasc anesthesia payments under the 2008 Physician Fee Schedule. I am grateful that CMS has recognized thc 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 unsusainable system in which anesthesiologists are being forced away from arcas with disproportionately high Medicare populations.

In an cffort to rcctify 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 undcrvaluation of anesthesia scrvices. I am pleased that the Agency accepted this recommcndation in its proposed rule, and 1 support full implementation of the RUC s recommendation.

To cnsure 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.


Page 238 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. charles hearn

Organization : Dr. charles hearn



Date: 07/26/2007

Impact

Impact

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

Rc: CMS- 1385-P Anesthcsia Coding (Pan of 5-Year Review)

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 REIRVS 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 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 effon to rcctifv this untenable situation. the RUC recommended that CMS increase the anesthesia conversion factor to offset a calculated 32 uercent work undervaluation a move that would result in increase of neariy $4.00 per anesthesia unit and serve as a major step forward in conecting the long-standing undervaluation of ancsthesia scrvices. I am pleased that the Agency acccpted this recommendation in its proposed rule, and I suppon full implcmcntation of thc RUC s recommendation.



Page 239 of 908 August 01 2007 11:33 AM

Submitter : Dr. Leslie Milde

Organization : Mayo Clinic



Date: 07/26/2007

GENERAL

GENERAL


Re: CMS-1385-P Anesthesia Coding ( P a 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 foward in comting the long-standing undervaluation of anesthesia services. I am pleased that thk 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 immcdiately implementing the anesthesia conversion factor increase as recommended by the RUC.


Leslic Milde, M.D. Professor of Anesthesiology

Page 240 of 908 August 01 2007 1 1 :33 AM

Submitter : Dr. David Berger

Organization : Dr. David Berger



Date: 07/26/2007

GENERAL

GENERAL

Dear Ms. Norwalk:


When the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to signiticant 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 cffon to rectify this untcnable situation, thc RUC recommended that CMS increase thc anesthcsia conversion factor to offset a calculated 32 pcrcent 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 undcrvaluation of anesthesia services. I am pleased that thc Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Page 24 1 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. Thomas Scozzafava

Organization : Dr. Thomas Scozzafava



GENERAL

GENERAL

see attachment

Page 242 of 908

Date: 07/26/2007

August 01 2007 1 1:33 AM


Re: CMS-1385-P


Dear Ms. Norwalk:






Submitter : Dr.




Date: 07/26/2007

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


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 rccognized 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 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 243 of 908 August 01 2007 11:33 AM

Submitter : Dr. Thomas Scozzalava

Organization : Dr. Thomas Scozzalava



GENERAL

GENERAL

see attachment

Date: 07/26/2007

Page 244 of 908 August 01 2007 1 1 :33 AM


Re: CMS-1385-P


Dear Ms. Norwalk:






Submitter : Dr. BobbieJean Sweiber Date: 07/26/2007

Organization : University of Chicago


Issue ~reas /~omments

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 1244-8018

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 $16.1 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 cffort 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 neariy $4.00 per anesthesia unit and serve as a major step fo~ward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency aceepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



BobbieJean Sweiher, M.D.

Page 245 of 908 August 01 2007 11:33 A M

Submitter : Date: 07/26/2007

Organization :

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 21244-801 8


Dear Ms. Norwalk:

I am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physieian 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 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 ,a 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.



Samuel Clay

Page 246 of 908 August 01 2007 1 1 :33 AM

Submitter : Dr. Martin Sznfran

Organization : University of Chicago



Date: 07/26/2007

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

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. Along with my patients, I am gratehl 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 10 years 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 folced away from areas with disproportionately high Medicare populations.

I bclicvc that thc pmposed increase of nearly $4.00 per anesthesia unit would serve as a major step forward in correcting thc long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this lecommendation in its pmposed rule, and I support full implementation of the RUC s recommendation. It will go a long way towards ensuring access to expert anesthesiology care in the future.

I urge CMS to follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


M. Szafran, M.D.

Page 247 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. Wendy Binstock

Organization : American Society of Anesthesiologist



Date: 07/26/2007

GENERAL

GENERAL

Dear Ms. Norwalk:

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 fmm areas with disproponionately high Medicare populations.


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.


Page 248 of 908 August 01 2007 1 1 :33 AM

Submitter : Mr. Kevin Paige Date: 07/26/2007

Organization : NA



GENERAL

GENERAL

As an individual, 1 am happy to see the recommendations that medicare payments are being adjusted upwards to reflect adequate compensation for anesthesiologists - a move which is long overdue. In order to provide the best medical care to our elderly population, we need to attract and retain the best physicians. Higher compensation will continue to draw the most talented people to the medical field, promoting bener care, greater discovery in research and better overall satisfaction for patients. As you know, anesthesiologists play an integral role in the care provided to our elderly, especially given the increased use of invasive procedures and surgeries to improve their health. 1 am encouraged to see my tax dollars at work in the correct manner, putting health care dollars in the hands of physicians who deliver the care.

Page 249 of 908 August 01 2007 11 :33 A M

Submitter : Dr. Charles Collard Date: 07/26/2007

Organization : Baylor College of Medicine





Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS- 1385-P P.0. Box 80 18 Baltimore, MD 2 1244-801 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 nations seniors, and is creating an msustainable 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 ha t 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.



Regards,

C. David Collard, MD Professor & Vice Chair Bay lor College of Medicine Department of Anesthesiology Texas Heart Institute 6720 Bertner Avenue, Room 0520 MC 1-226 Houston, TX 77030

Telephone: 832-355-2666 Fax: 832-355-6500

Page 250 of 908 August 01 2007 1 1 :33 A M

Submitter : Dr. Saraswathy Shekar Date: 07/26/2007

Organization : Dr. Saraswatby Shekar



GENERAL

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


Dear Ms. Nonvalk:






Sara Shekar

Page 25 1 of 908 August 01 2007 11 :33 AM

Submitter : Dr. Terrence Trentman Date: 07/26/2007

Organization : Dr. Terrence Trentman



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 1244-80 18


Dear Ms. Nonvalk:



In an effort to rectify this untenable situation, the RUC recommended that CMS increasc 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.



Page 252 of 908 August 01 2007 1 1 :33 A M

Submitter : Dr. Craig Wagner Date: 07/26/2007

Organization : South Jersey Anesthesia and Pain Physicians PC



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 21244-8018


Dear Ms. Norwalk:

1 am writing to express my strongest support for the proposal to increasc anesthesia payments under thc 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 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 $1 6.19 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 perccnt 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 253 of 908 August 01 2007 11:33 AM

Submitter : Dr. Loran Mounir Soliman

Organization : Cleveland Clinic Ohio



GENERAL

Date: 07/26/2007

GENERAL

Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 80 1 8 Baltimore, MD 21244-801 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 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 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 arcas 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 neatly $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 254 of 908 August 01 2007 1 1 :33 AM

Submitter : Dr. James Berny




Date: 07/26/2007



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:


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 $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 fmm arcas with disproportionately high Mcdicare populations.

In an cffort to rectify this untenable situation, the RUC recommended that CMS increasc 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 acceptcd this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.



Dr. James Bemy MD

Page 255 of 908 August 01 2007 1 1:33 A M

Submitter : Dr. Eric Buehler


Category : Health Care Professional or Association


GENERAL

GENERAL

commentlettertemplate-I .doc

Page 256 of 908

Date: 07/26/2007

August 0 1 2007 1 1 :33 AM

Submitter : Mr. Peter Kearns CRNA Date: 07/26/2007

Organization : American Association of Nurse Anesthetists

Category : Nurse Practitioner

Issue Areas/Commeots



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

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

Dcar Ms. Norwalk:

I am writing to express my strongest support for the proposal to increase anesthesia paymcnts 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 stcps to addrcss this complicated issue.

Whcn the RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work comparcd to other physician services. Today, more than a dccade 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 arcas 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 perccnt 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 services. I am pleased that the Agency accepted this recommendation in its proposed rulc, and I support full i~nplemcntation of thc RUC s recommendation.

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


Petcr Keams CRNA

Page 257 of 908 August 01 2007 1 1:33 AM

Submitter : Mr. Joseph Giampietro CRNA Date: 07/26/2007






Leslie V. Nonvalk, Esq. Acting Administrator Ccnters 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 shongest 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.

Whcn thc RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physieian 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 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 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 medieal eare, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immediately implementing the anesthesia conversion faetor increase as recommended by the RUC.


Joscph Giampieho CRNA

Page 258 of 908 August 01 2007 1 1:33 AM

Submitter : Miss. Tracy Osborn



Date: 07/26/2007






Dear Ms. Nonvalk:


Whcn thc RBRVS was instituted, it creatcd a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to othcr physician serviccs. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.1 9 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 disproportionately high Medicare populations.

In an effort to rectify this untenable situation, thc RUC recommended that CMS increase the ancsthesia 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 expert anesthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immcdiately implementing the anesthesia conversion factor increase as recommended by the RUC.


Tracy Osborn CRNA

Page 259 of 908 August 01 2007 11:33 A M

Submitter : Mrs. Dawn Holloway Date: 07/26/2007 Organization : American Association of Nurse Anesthetists





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 1244-801 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 rccognizcd the gross undervaluation of anesthesia services, and that the Agency is taking steps to address this complicated issue.

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 $16.1 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 ale 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 lesult in an inclease 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 mmmendation.



Dawn Holloway CRNA

Page 260 of 908 August 01 2007 11:33 AM

Submitter : Dr. Chinubhai Patel Date: 07/26/2007

Organization : Preferred Anesthesia Consultants, P.C.



GENERAL

GENERAL

Lcslic 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:


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 $1 6.1 9 per unit. This amount does not cover 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.


To ensure that our patien6 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.


Sinccrcly.

Chinubhai Patel, MD Prcferrcd Anesthesia Consultants. P.C.

Page 261 of 908 August 01 2007 11:33 AM

Submitter : Dr. Seetharamaiah Atluri Date: 07/26/2007




GENERAL

GENERAL

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


Dear Ms. Norwalk:

1 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 rccognizcd the gross undervaluation of anesthesia services, and that thc Agency is taking stcps to addrcss this complicated issue.

Whcn the RBRVS was instituted, it created a hugc payment disparity for anesthesia care, mostly due to significant undcrvaluation of anesthcsia work compared to othcr physician scrviccs. Today, morc than a decade sincc the RBRVS took cffect, Mcdicarc payment for anesthcsia scrvices stands at just $16.1 9 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 arcas with disproportionately high Mcdicare populations.

In an cffort to rectify this untenable situation, the RUC recommended that CMS increase the anesthesia convcaion 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 proposcd mle, and I support full implementation of the RUC s recommendation.



Sincerely,

Seetharamaiah Atluri, M.D.

Page 262 of 908 August 01 2007 11:33 AM

Submitter : Dr. Robert Davis Date: 07/26/2007

Organization : American Academy of Pediatric Dentists





Lcslie 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:


Whcn the RBRVS was instituted, it created a huge paymcnt disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to other physician services. Today, more than a decade since the REJRVS 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 disabled and handicapped, 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 wmcting 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 cnsure that our patients 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.

Thank you for your considcration of this serious matter.

Dr. Robert Davis DMD

Page 263 of 908 August 01 2007 11:33 AM

Submitter : Dr. David Peng Date: 07/26/2007

Organization : Dr. David Peng



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 2 1244-801 8


Dear Ms. Nonvalk:


Whcn the RBRVS was institutcd, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work compared to othcr physician scrvices. Today, more than a decade since the RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 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 fmm arcas with disproportionately high Medicare populations.




Page 264 of 908 August 01 2007 11:33 A M

Submitter : Dr. Robert Goldstrom

Organization : Dr. Robert Goldstrom



Date: 07/26/2007

GENERAL

GENERAL

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


Dear Ms. Nonvalk:

I am writing to express my seongest 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 6.19 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 proposcd 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 impemtive 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 scrious matter.

Sincerely,

Robert Goldstrom, M.D.

Page 265 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. Pardha Kanagala




Date: 07/26/2007

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 1244-8018

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

Dear Ms. Nonvalk:

I am writing to exprcss my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fce Schcdule. I am grateful that CMS has rccognizcd thc gross undervaluation of anesthesia services, and that the Agency is taking stcps to address this complicated issue.

When thc RBRVS was instituted, it created a huge payment disparity for anesthesia care, mostly due to significant undervaluation of anesthesia work comparcd to othcr physician scrviccs. 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 1 support full implementation of the RUC s recommendation.

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

Thank you for your considcration of this serious matter

Sincerely,

Pardha Kanagala, M.D.

Page 266 of 908 August 01 2007 11:33 A M

Submitter : Dr. zoya mehta

Organization : MACC



GENERAL

Date: 07/26/2007

GENERAL

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


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 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 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 reeommendation 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 ancsthcsia eonversion factor increase as recommended by the RUC.


Zoya Mehta M.D.

Page 267 of 908 August 01 2007 11:33 AM

Submitter : Dr. Terrence Zipfel Date: 07/26/2007

Organization : American Society of Otolaryngology







Dear Ms. Norwalk:

1 am writing to express my strongest support for the proposal to increase ancsthesia payments under the 2008 Physician Fec Schedule. 1 am grateful that CMS has recognized the gross undervaluation of ancsthesia services, and that the Agency is taking steps to address this complicatcd 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, disabled, and handicapped, and is creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.

In an cffort 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 cnsure 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 implcmcnting thc ancsthesia conversion factor increase as recommended by the RUC.


Dr. Terrencc Zipfel MD

Page 268 of 908 August 0 1 2007 1 1 :33 AM

Submitter : Dr. Venkateswara Kanubaddi




Date: 07/26/2007

GENERAL

GENERAL

Leslie V. Nonvalk, Esq. Acting Administrator Ccnters for Medicare 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. 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.





Sincerely,

Vcnkateswara Kanubaddi, M.D.

Page 269 o f 908 August 01 2007 11 :33 AM

Submitter : Dr. D'Andrae Douse




Date: 07/26/2007

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

Rc: CMS- 1385-P Anesthcsia Coding (Part of 5-Year Review)

Dcar 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 inerease 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 cnsure 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 immcdiatcly implementing the anesthesia conversion factor increase as recommended by the RUC.


Sincerely,

D'Andrae Douse. M.D.

Page 270 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. Gerald Snyder




Date: 07/26/2007

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 21244-801 8


Dear Ms. Nonvalk:




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.


Sincerely,

Gerald Snyder, M.D.

Page 27 1 of 908 August 01 2007 1 1 :33 AM

Submitter : Dr. Kian Porter




Date: 07/26/2007

GENERAL

GENERAL



Dear Ms. Nonvalk:


When thc REJRVS 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 dicade since the REJRVS 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 wnecting the long-standing undcrvaluation of ancsthesia 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 cnsurc that our patients havc access to expert ancsthesiology medical care, it is imperative that CMS follow through with the proposal in the Federal Register by fully and immcdiately implementing thc anesthesia conversion factor increase as recommended by the RUC.


Sinccrely,

Kian Porter, M.D.

Page 272 of 908 August 01 2007 1 1 :33 AM

Submitter : Dr. James DeSimone




Date: 07/26/2007

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 21 244-801 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 thc 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 converjion 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.



Sincerely,

James DeSimone. M.D.

Page 273 of 908 August 01 2007 11:33 AM

Submitter : Dr. Rao Gummadi




Date: 07/26/2007

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


Dear Ms. Norwalk:

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 $16.19 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 arcas 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-sfanding 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.



Sincerely,

Rao Gummadi. M.D.

Page 274 of 908 August 01 2007 11:33 AM

Submitter : Dr. Zoya Mehta

Organization : MACC



Date: 07/26/2007

GENERAL

GENERAL

Leslie V. Norwalk, Esq. Acting Administrator Ccnters for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 8018 Baltimorc, 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 physieian 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 1 support full implementation of the RUC s recommendation.



ZOya Mehta

Page 275 of 908 August 01 2007 1 1 :33 AM

Submitter : Dr. Louis Knoble




Date: 07/26/2007

GENERAL

GENERAL



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 neady $4.00 per anesthesia unit and serve as a major step forward in correcting the long-standing undcrvaluation 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,

Louis Knoble, M.D.

Page 276 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. Brian Jenkins




Date: 07/26/2007

GENERAL

GENERAL


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

Dcar 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 neally $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,

Brian Jenkins. M.D.

Page 277 of 908 August 01 2007 11:33 AM

Submitter : Dr. Joseph Yurkanin




Date: 07/26/2007

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 1244-80 18

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

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 recognizcd 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 comparcd to othcr 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 scrvices. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of thc RUC s recommendation.

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


Sincerely,

Joscph Yurkanin, M.D.

Page 278 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. Michael Yurkanin




GENERAL

Date: 07/26/2007

GENERAL

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

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

Dcar Ms. Norwalk:


Whm 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 arcas with disproportionately high Medicare populations.

In an cffort to rcctifv this untenable situation. the RUC recommmded that CMS increase the anesthesia conversion factor to offset a calculated 32 percent work undervaluation a move that would result in 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 rulc, 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 Rcgister by fully and immediately implementing the anesthesia conversion factor increase as recommcnded by thc RUC.


Sincerely,

Michael Yurkanin, M.D.

Page 279 of 908 August 01 2007 11:33 AM

Submitter : Dr. Edward Tompa




GENERAL

Date: 07/26/2007

GENERAL Leslie V. Norwalk, Esq. Acting Adminishator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 80 18 Baltimore, MD 21244-8018


Dcar Ms. Nonvalk:


When the RBRVS was instituted, it crcated 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 fotward in correcting the long-standing undervaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed ~ l e , and 1 support full implementation of thc RUC s recommendation.

To cnsure that our patients havc 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.


Sincerely,

Edward Tompa, M.D

Page 280 o f 908 August 01 2007 1 1 :33 AM

Submitter : Dr. Ramabrahmam Gullapalli




Date: 07/26/2007

GENERAL

GENERAL

Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-I 385-P P.O. Box 801 8 Baltimore, MD 2 1244-801 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 $16.1 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 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 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 1 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 Fedcral Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Sincerely,

Ramabrahmam Gullapalli, M.D.

Page 28 1 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. Scott Davis




GENERAL

Date: 07/26/2007

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 1244-8018


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 eompared 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 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 incrcase 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.

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


Sincerely,

Scott Davis, M.D.

Page 282 of 908 August 01 2007 11:33 AM

Submitter : Dr. Venkatarao Vemula




Date: 07/26/2007

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 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, Medieare 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 rcctify 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 serviees. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.

To cnsurc 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.


Sinccrcly,

Vcnkatarao Vemula, M.D.

Page 283 of 908 August 01 2007 11:33 AM

Submitter : Dr. David Donaldson Date: 07/26/2007




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


Dcar Ms. Nonvalk:

I am writing to express my strongest support for the proposal to incrcasc 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 thc RBRVS took effect, Medicare payment for anesthesia services stands at just $16.19 per unit. This amount does not cover the wstof caring for our nation s seniors, and is creating an unsustainible system in which anesthesiologists aRbeing forced away from areas with disproportionately high Medicare populations.

In an effort to rectify this untenable situation, the RUC rcwmmended 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 anesthcsia 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 cnsure 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 anesthcsia conversion factor increase. as recommended by the RUC.


Sincerely,

David Donaldson, M.D.

Page 284 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. Ray Tople



Date: 07/26/2007


GENERAL

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

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

Dear Ms. Nonvalk:

I am writing to express my strongest support for the proposal to increase anesthesia paymcnts 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 comparcd 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 undcrvaluation of anesthesia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of thc 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 Fedcral Register by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Sincerely,

Ray Tople, M.D.

Page 285 of 908 August 01 2007 1 1 :33 A M

Submitter : Mrs. Marilyn Bowes Date: 07/26/2007

Organization : N/A



GENERAL

GENERAL

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:

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 ereated 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 serviees 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 reetify this untenable situation, the RUC recommended that CMS inerease the anesthesia eonversion factor to offset a calculated 32 percent work undervaluation a move that would result in an increase of nearly $4.G€l 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.

I'm sure that you're aware that Medicare patients are among the sickest, with the most co-morbidities, and arc the most likely to need the very best of anesthesiologists. If we continue to limit reimbursement, will thcrc bc anyone at the ready when you or I need a qualified anesthesiologist to attend us for our own procedure? To ensure that patients have access to expert anesthesiology medieal 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.


Marilyn R. Bowes

Page 286 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. Satya Tummala



lssue AreasIComments

Date: 07/26/2007

GENERAL

GENERAL Leslie V. Norwalk, Esq. Acting Administrator Centers for Medicare and Medicaid Services Attention: CMS-1385-P P.O. Box 80 18 Baltimore, MD 21 244-80 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 creating an unsustainable system in which anesthesiologists are being forced away from areas with disproportionately high Medicare populations.


To cnsure that our patients have acccss to expcrt 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 faetor increase as recommended by the RUC.


Sinccrely,

Satya Turnmala, M.D.

Page 287 of 908 August 01 2007 1 1 :33 AM

Submitter : Dr. Alton Liu




Date: 07/26/2007

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

Rc: CMS- 1385-P Ancsthcsia Coding (Part of 5-Ycar Review)

Dcar Ms. Norwalk:

I am writing to cxpress my strongest support for the proposal to increase anesthesia payments under thc 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 ancsthesia 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 undcrvaluation 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 thc Federal Registcr by fully and immediately implementing the anesthesia conversion factor increase as recommended by the RUC.


Sincerely,

Alton Liu, M.D.

Page 288 of 908 August 01 2007 11 :33 AM

Submitter : Dr. Magdy Toma




GENERAL

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


Date: 07/26/2007

I 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 perccnt 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 pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of the RUC s recommendation.

To ensurc 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.


Sincerely,

Magdy Toma, M.D.

Page 289 of 908 August 01 2007 1 1:33 AM

Submitter : daniel obrien

Organization : daniel obrien



GENERAL

GENERAL see attachment

Date: 07/26/2007

Page 290 of 908 August 01 2007 1 1:33 AM

Submitter : Dr. James Alifimoff




Date: 07/26/2007

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

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

Dear Ms. Norwalk:






Sincerely,

James Alifimoff* M.D.

Page 291 of 908 August 01 2007 11:33 AM

Submitter : Dr. Anthony Cheng




Date: 07/26/2007

GENERAL

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

Rc: CMS-1385-P Anesthcsia Coding (Pan of 5-Ycar Review)

Dcar Ms. Norwalk:

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

When the RBRVS was instituted, it ereated 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 cffecf Medicare payment for anesthesia services stands at just S 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 anesthcsia services. I am pleased that the Agency accepted this recommendation in its proposed rule, and I support full implementation of thc RUC s recommendation.

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


Sincerely,

Anthony Cheng, M.D.

Page 292 of 908 August 01 2007 11:33 AM

Date: 07/26/2007 Submitter : Dr. Michael Coni




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 1244-80 18

Rc: CMS-1385-P Ancsthcsia Coding (Part of 5-Year Rcview)

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 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 physieian 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 mlc, and I support full implementation of the RUC s recommendation.



Sincerely,

Michael Cozzi, M.D.

Page 293 of 908 August 01 2007 11:33AM

Submitter : Dr. Gil Mendoza




Date: 07/26/2007

GENERAL

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

Rc: 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 ancsthesia 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,

Gil Mendoza, M.D.

Page 294 o f 908 August 01 2007 11 :33 AM

Submitter : Dr. Garry Walker




Date: 07/26/2007

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 21244-8018


Dear Ms. Norwalk:

1 am writing to express my strongest support for the proposal to increase anesthesia payments under the 2008 Physician Fce 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 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 undcrvaluation 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.



Sincerely,

Gany Walker, M.D.

Page 295 of 908 August 01 2007 1 1:33 AM

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