April 7, 2000
Mr. Tom Gustafson
Director, Purchasing Policy Group
Health Care Financing Administration
7500 Security Boulevard
Baltimore, MD 21207
RE: Response to the HCFA Relations on Prospective Payment for Outpatients
OPPS Final Ruling in Federal Registry on April 7
Dear Mr. Gustafson,
I am responding to HCFA's final rule OPPS on Observation not being included in the APC category. I am the President of the Society of Chest Pain Centers and Providers. Currently there are over 1200 Chest Pain Centers in the United States. The growth of these units has exponentially taken place in the last 10 years and it has been predicted that most of the 5000 hospitals in the United States will have a Chest Pain Center by the year 2003. The reason for the growth in Chest Pain Centers has to do with setting up a system of Heart Attack Care, similar to the safety system now being requested by the Clinton Administration to reduce errors within hospitals. In his report he asked that a Center for Quality and Safety be instituted and that each hospital put together Guidelines and Protocols to reduce hospital error.
Heart attack is the number one health problem in the United States and is the number one killer of the adult population. It has been that way since the turn of the century. Chest Pain Centers represent a comprehensive management of patients presenting with chest pain as a way to get to the heart attack problem. The requirements for Chest Pain Centers has been listed in the American Journal of Cardiology (enclosed). One of the requirements is to have an Observation Area in the Emergency Room in order to reduce inappropriate admissions to the hospital as well as to reduce the number of missed MI's being sent home. As one can see both of these steps help to prevent errors in hospitals. Most importantly these centers have been cost effective and have been so reported in peer review journals within the last year (enclosed).
Thus what has come about with Chest Pain Centers is a comprehensive management of heart attack at the community hospital level as a way to reduce error by preventing inappropriate admissions and missed MI's while reducing overall health care cost (the cost of an observation ruleout is 1/3rd that of a hospital admission). Errors are thus reduced.......lives are saved....... waste is prevented....... and we improve overall heart attack care within the United States.
The present ruling that goes into effect will essentially nullify the medical progress in Chest Pain Centers over the last ten years and will be very harmful to the American Public and increase the number of deaths due to missed MI diagnosis. It will certainly increase overall health costs by promoting admissions of chest pain patients through the Emergency Room (wasteful) and most importantly it will take away the efforts being made to shift the paradigm of heart attack care to acute prevention of death and damage to the heart muscle.
It is important to truly understand what HCFA is doing in attempting to put this policy into effect. It will be in direct conflict with the Clinton Administration's policy of error reduction and needed safety systems needed to be implemented in hospitals throughout the United States. It certainly does not reflect the importance of Chest Pain Centers as recently put together at the 31st ACC Bethesda Conference on Emergency Cardiac Care regarding the value added aspect of Chest Pain Centers (enclosed) nor does it reflect the recent plan in the State of Maryland for Cardiovascular Services that encourages Chest Pain Centers and awareness programs to be part of all Maryland hospitals in order to improve heart attack care.
It would be helpful to know what references the HCFA Committee used to make this final decision supporting their conclusions. I would ask that we have a meeting within a short period of time and involve not only the Society of Chest Pain Centers but also the American College of Cardiology, the American College of Emergency Physicians, the American Society of Nuclear Cardiology and the American Heart Association in an effort to resolve these issues so stated above so as to prevent a need to carry this more informative viewpoint to a higher level.
It is important to understand this ruling is in direct conflict with the Clinton Administration's proposed Center for Quality and Error Reduction now being requested to be instituted in every hospital in the United States.
It would be helpful to include also the United States Public Health Service, (Dr. Satcher) as well as other government administrators concerned with the Public Health of our citizens not only in terms of safety but also in terms of reducing heart attack deaths from being the number one health problem within United States.
The Chest Pain Center Strategy has now become successful through evidence based discoveries published in peer reviewed articles in the medical literature as well as having the recent consensus of the American College of Cardiology at the 31st Bethesda Conference on Emergency Cardiac Care.
Sincerely and Respectfully,
Raymond D. Bahr, MD
President
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cc:
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Board of Trustees, Society of Chest Pain Centers and Providers
Arthur Garson, MD, President American College of Cardiology
George A. Beller, MD, President Elect, American College of Cardiology
James E. Udelson, MD, President, American Society of Nuclear Cardiology
Lynn Smaha, MD, President, American Heart Association
Michael A. Rapp, MD, American College of Emergency Physicians
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