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2006 proposed fee schedule - American Society of Clinical Oncology

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anesthesia programs that have arranged their practices to<br />

meet the conditions necessary to bill under the revised<br />

policy. The ASA suggests that the teaching physician<br />

121<br />

regulations for teaching anesthesiologists should be similar<br />

to those for teaching surgeons for overlapping complex<br />

surgery procedures. The ASA thinks that anesthesia is<br />

similar to complex surgery in terms <strong>of</strong> critical periods,<br />

overlap, and availability <strong>of</strong> teaching physicians. However,<br />

the critical portions <strong>of</strong> the teaching anesthesia service and<br />

the critical portions <strong>of</strong> the teaching surgeon service are<br />

not the same. The ASA believes that inadequate payment<br />

levels have contributed to the loss <strong>of</strong> teaching<br />

anesthesiologists and an inability to recruit new faculty.<br />

We are requesting comments on a teaching physician<br />

policy for anesthesiologists that could build on the policy<br />

announced in the November 7, 2003 PFS final rule, but<br />

provide the appropriate revisions that would allow it to be<br />

more flexible for teaching anesthesia programs. We would<br />

also be interested in receiving data and studies relevant to<br />

this issue as well as any <strong>of</strong>fsetting savings that could be<br />

made to account for any potential costs that could be<br />

incurred if there was a policy change.<br />

G. End Stage Renal Disease (ESRD) Related Provisions<br />

On November 15, 2004, we published the Revisions to<br />

Payment Policies Under the Physician Fee Schedule for

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