ASCRS - OOSS 5YR and PE Comment letterFINAL

AMERICAN SOCIETY OF CATARACT AND REFRACTIVE SURGERY OUTPATIENT OPHTHALMIC SURGERY SOCIETY August 21, 2006 Mark McClellan, MD, PhD Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Hubert H. Humphrey Building ATTN: CMS-1512-PN 200 Independence Avenue Room 445-G Washington, DC 20201 Re: CMS-1512-PN; Medicare Program; Five-Year Review of Work Relative Value Units Under the Physician Fee Schedule and Proposed Changes to the Practice Expense Methodology Dear Dr. McClellan: The American Society of Cataract and Refractive Surgery (ASCRS) represents over 9,500 ophthalmologists in the United States and abroad who share a particular interest in cataract and refractive surgical care. ASCRS members perform the vast majority of cataract procedures done annually in the United States. The Outpatient Ophthalmic Surgery Society (OOSS) is a professional medical association of over 900 ophthalmologists, nurses, and administrators who specialize in providing high-quality ophthalmic surgical procedures performed in cost-effective outpatient environments, including ambulatory surgical centers (ASCs). ASCRS and OOSS appreciate the opportunity to submit comments on the proposed rule for the five-year review of work relative value units and changes to the practice expense methodology. Five-Year Review of Work Relative Value Units Application of the ...