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We need to respond as a profession and submit letters and comments to the committee concerning this amendment. Below is the process to do this and I encourage everyone to take a little time and write a letter. This amendment will affect all of us at some level if it is passed.
Remember that this is being supported and pushed by the APTA, however, that does not mean that all PT’s feel this is appropriate or share the views of their organization. Many PT’s, and I would venture to say MOST, believe that ATC’s provide a very needed and professional medical service. We should not feel attacked by all PT’s and thus try to alienate ourselves from them or in any way criticize their profession. They are our colleagues in many ways and we should be working together and with each other for the betterment of patient care.
There are several points that can be included or spoken to in your letter – these are listed below and are sanctioned by the NATA and its governmental affairs division.
“Incident to” has been around since 1965 and the inception of Medicare. Physicians have the right to delegate care of their patients to any medical profession they deem knowledgeable and trained to provide those services. Physicians must have the ability to determine the best individual for their patients to see. It is in the best interest of patient care that this is done. This can lead to delayed care, as patients will need to schedule outside the office or not have access at all to what the physician has deemed appropriate care. These delays can lead to increased medical costs, due to lack of care, and possibly patients not receiving the care they need.
Remember to include that Athletic Trainers are highly educated professionals. They must graduate from accredited athletic training programs to be eligible to sit for the national board certification exam. These programs are accredited by the Commission on Accreditation of Allied Health Education Programs (CAAHEP) via the Joint Review Commission on educational programs in Athletic Training (JRC-AT). One of the biggest arguments our opponents are using is that we are not educated enough to be able to provide these services. They argue that there is a lack of educational standards. This is simply not true and must be pointed out.
We are simply trying to argue that we provide a valuable service that patients and physicians want to access. We also ask that your supervising physicians and even your patients write in to support the defeat of this amendment. This is up to us to make this amendment not pass.
Letters must be received by 5pm on September 24.
To file on line: go to the web site http://www.cms.hhs.gov/regulations/ecomments/
- Click on Send
- Click on CMS 1429-P, Click go or submit
- Accurately fill in the Document Management Comment Form
- Click continue, then click issue 20-29
- In the “incident to” section either type in a less than 4000 character comment or write, “see attached letter”. Click on continue at the bottom of the page.
- Browse for attachment and indicate what format you used. (word, word perfect, etc…)
- Click the yellow attach file button and then click save comments.
To send written comments:
- Mail one original and two copies to the following address:
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Attention: CMS-1429- P, P.O. Box 80122
Baltimore, MD 21244-8012
Please try and take the time to help out your profession. I appreciate your assistance. Thank you.
Paul Bruning, MA ATC/R EMT-B
President
Minnesota Athletic Trainers Association
For More information please go to www.nata.org
~ View the letter that Paul Bruning wrote to the CMS ~ |
