CMS Deadline for Comments

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FYI... see below.


Justin Milici, RN, MSN, CCRN, CEN, CFRN, TNS
Trauma Education, Prevention/Outreach
Trauma Services - 11 Roberts
Baylor University Medical Center
3500 Gaston Ave.
Dallas, TX 75246
(214) 820-6818
(214) 820-1086 - Fax
(214) 344-3961 - Pager
E-mail: JustinM at baylorhealth.edu



________________________________
From: Scott Parsley [mailto:sparsley at kellerfd.com]
Sent: Friday, December 28, 2007 11:09 AM
To: Milici, Justin J.
Subject: CMS Deadline for Comments

Hi Justin,

While the rule from CMS is driven towards ambulance services it too has an impact on receiving ER staff.

For anyone so inclined to comment back to CMS here is a link and some discussion points.

Thanks!
________________________________
From: Scott Parsley
Sent: Friday, December 28, 2007 9:27 AM
To: tcemspo at yahoogroups.com
Subject: CMS Deadline for Comments

The deadline to submit comments on the proposed changes to the ambulance provider rule requiring signatures above and beyond what is normally accepted is midnight on Monday.

You can copy this link below and paste it into your browser to navigate to the CMS website and enter your comments.

http://www.accessdata.fda.gov/scripts/oc/dockets/comments/getDocketInfo.cfm?EC_DOCUMENT_ID=165&SORT=&MAXROWS=15&START=1&CID=&AGENCY=CMS


When submitting your comments you have the opportunity to submit for not only yourself but for a professional association.  Being that TCEMSPO meets that standard I would request that an officer from our organization submit a comment on behalf of the organization in opposition to the proposed changes.

The proposed changes would require transport crews to spend additional out of service time attempting to obtain documentation above and beyond the current rule as well as burdening ill or injured patients, distressed family members and taking emergency department staff away from their role as care providers to satisfy compliance with this rule.

If this rule change is implemented it will still need CMS oversight and auditing for compliance and enforcement, no less than what the current rule requires.

Instead of implementing this rule it would be preferred that CMS exercise greater enforcement of the current rule on those who are not in compliance instead of shifting the burden back onto those who do comply.




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