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Florida Chapter
American College of Cardiology
September 4, 2009
The Honorable Kathleen Sebelius
Secretary
US Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201
Dear Secretary Sebelius:
Cardiovascular specialists physicians of Florida and the Florida Chapter of the American College of Cardiology (FCACC) are in strong opposition to the proposed Medicare 2010 rule change, especially in relation to cardiovascular services. The Centers for Medicare and Medicaid Services (CMS) proposal will result directly in a serious reduction in ACCESS TO CARE and QUALITY OF CARE and will actually INCREASE THE COST to CMS as many of these outpatient services are transformed from an outpatient to an inpatient setting.
The American College of Cardiology (ACC) has presented documentation that the physician proactive information survey (PPIS) data and methodology used in the development of the practice expense values in this rule are flawed. The serious deficiencies in the survey include the following: (1) the sample size was extraordinarily small and cannot be utilized in any manner to be statistically representative, (2) the survey lacks transparency and we have had no opportunity to critically review the entire survey data, (3) the finding that practice expenses have decreased is an obvious contradiction to all other measures (including prior CMS data). In fact, almost all physicians in Florida continue to experience significant increases in cost of practice.
As cardiologists, we continue to be committed to medical care for ALL cardiovascular patients, in compliance with published ACC practice guidelines and appropriateness guidelines (J Am Coll Cardiol 2009; 53: 2201-2229. J Am Coll Cardiol 2007; 50: 187-204.). Theses guidelines help insure that Medicare beneficiaries receive diagnostic imaging services that are consistent with an evidence-based approach to care.
In summary, the below signed cardiovascular physicians and cardiovascular care associates are united in firm opposition to the proposed Medicare 2010 rules change.
Sincerely,
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