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Help Stop New Ultrasound Restrictions by Aug. 29thFrom: GIN11153@aol.comThu Aug 28 03:42:57 2008
for those of you who did not receive this from ACOG: URGENT NEWS - YOUR ACTION NEEDED BY AUGUST 29 ACOG President Douglas H. Kirkpatrick, MD: "Help Stop New Ultrasound Restrictions! Your Practice, and Our Specialty, May Be At Risk." A new proposal by Medicare officials threatens to disqualify you from billing Medicare for obstetric and gynecologic ultrasound services. Because private payers often follow Medicare rules, this proposal may affect nearly all ob-gyn practices. With your help, ACOG successfully fought efforts in Congress to restrict ob-gyn ultrasound. Together, we'll defeat this effort by the Bush Administration too. Physician offices that provide and receive payment for imaging services would have to meet the regulatory standards of and enroll as Independent Diagnostic Testing Facilities (IDTFs). This means that: * Your office would have to apply to become an IDTF, meet new staff training requirements, submit to unscheduled inspections, and meet other requirements. * You may have to employ a radiologist as a "supervising physician." * Medicare could disallow you from billing for ultrasound services at any time. Want to know more? Read the whole proposal in the attached PDF document. I urge all ACOG members to join us in fighting this terrible idea. Send your comments of opposition to the Center for Medicare and Medicaid Services (CMS) before August 29, 2008. That's right only one week from today! Your message to CMS: Withdraw any effort to force ob-gyn practices to become IDTFs. Here's how: * Attached, you'll find a suggested comment letter, already addressed to the appropriate individual at CMS. * Please fill in the blanks regarding your practice and your experience with in-office ultrasound. * Put the final letter on your practice's letterhead. * Comments must be submitted electronically as a PDF or a Word document no later than 5:00 pm EST on August 29, 2008. * Go to _http://www.regulations.gov_ (http://www.regulations.gov/) . In the box entitled "Comment or Submission" enter the filecode [CMS-1403-P] to find the appropriate document accepting comments. * Click on the "Send a Comment or Submission" link. After providing identifying information, locate your letter at the bottom of the form using the browse feature. * After locating the file you wish to attach, click the "add attachment" button. * CMS will not accept facsimile (FAX) transmissions. * Be sure to fax or email a copy of your letter to ACOG at 202-488-3985 or _govtrel@acog.org_ (mailto:govtrel@acog.org) . Background: * Every year, the Centers for Medicare and Medicaid Services (CMS) proposes new rules governing Medicare physician payments for the following calendar year. The public has 60 days to comment, writing to CMS on the impact of the proposal on physicians. CMS publishes the final rule around November 1. * CMS is required by law to review each comment it receives, and comments from the physician community can have a tremendous influence on the final outcome. * Proposed expansion of Independent Diagnostic Testing Facility status to physician offices would create a de facto privileging program using clinical specialty, not training, education or competence as the basis for granting privileges. ACOG strongly opposes this effort. Under the section entitled "Independent Diagnostic Testing Facilities," CMS proposes to require physician offices that provide and receive payment for imaging services to meet the regulatory standards of and enroll as an Independent Diagnostic Testing Facility (IDTF). These standards require the IDTF to contract with a qualified physician to supervise the performance of the imaging services. Qualifications to act as supervisor are established by the carrier and based upon medical specialty. Although carrier determinations vary somewhat, in many instances, the physician providing the care is excluded from supervising the imaging studies related to that care. For example, ob-gyns may not be deemed capable of supervising obstetric ultrasound and breast surgeons are may not be deemed capable of supervising breast ultrasound. IDTF rules also require applicants to be inspected by the carrier prior to enrollment, a common source of delay. This proposal would severely disrupt our ability to care for our patients. Take time today to get your comments in to CMS, telling CMS to withdraw its proposal to force ob-gyn practices to become IDTFs! Jeannie A. Conry, MD, PhD ACOG District IX, Chair
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