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CMS-1403-FC
commenters requested that we withdraw both the CY 2008 PFS
rulemaking and the current proposals. Other commenters
offered varied support or criticism for one or both of the
proposed alternatives. Some commenters expressed concerns
about eliminating legitimate, nonabusive arrangements that
serve Medicare beneficiaries. Quality concerns were raised
by commenters both in favor of and opposed to the
proposals.
Commenters in support of Alternative 1 believe that it
would be more straightforward and easier to implement than
Alternative 2. Some commenters responded to Alternative 1
by requesting that a physician be able to “share a
practice” with up to 3 physicians or physician
organizations in order to accommodate arrangements that
currently exist among many part-time physicians and the
groups for whom they work. These commenters also stated
that they would no longer be able to support an in-office
laboratory employing part-time physicians if the
Alternative 1 approach was implemented as proposed.
Some commenters offered support for Alternative 2 and
its “site-of-service” approach, which they argued would
curb abusive overutilization while granting physicians more
flexibility in how to structure arrangements to provide
care as they see fit. Commenters opposed to Alternative 2
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