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<strong>CMS</strong>-1403-FC<br />

qualifications for HHAs at §484.4. <strong>This</strong> change would align<br />

CORF personnel requirements not only with HHA requirements,<br />

but also with other regulations in Part 485 addressing<br />

provision of physical therapy, speech-language pathology,<br />

and occupational therapy services.<br />

Also, at 485.58(a)(1)(i), we proposed to amend the<br />

duties of a CORF physician to include medical supervision<br />

of nonphysician staff. <strong>This</strong> change conforms to changes<br />

made to the CORF conditions for coverage in the CY 2008 PFS<br />

final rule with comment period. We believe that adding<br />

medical supervision of nonphysician staff to the duties of<br />

CORF physicians more accurately reflects the duties and<br />

responsibilities of the CORF physician. We also believe<br />

that this change could increase the quality of care<br />

provided to patients of CORFs.<br />

The following is a summary of the comments received<br />

concerning Personnel Qualifications and our responses.<br />

Comment: Commenters generally supported our proposed<br />

changes. We received a comment that supported the spirit<br />

of our proposed changes to the definitions of respiratory<br />

therapists and provided further clarification regarding<br />

current professional standards. Specifically, in previous<br />

comments, the commenter noted that the term “respiratory<br />

therapy technician” is an obsolete term. <strong>This</strong> is because<br />

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