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CMS-1403-FC
medical records management for services performed within
their practices as those practices that utilize an outside
supplier for the TCs or PCs of their tests.
Response: We are unclear as to what the commenter is
suggesting. We did not propose to, and this final rule
does not, impose tighter billing restrictions on TCs and
PCs ordered by dermatologic surgeons than for other
specialties, and does not impose tighter billing
restrictions for dermatologic surgeons who perform TCs and
PCs than it does for those physician practices that
purchase TCs and PCs from an outside supplier. We note
that the commenter did not provide an explanation of why
patient access to care in rural or underserved areas would
be affected by our proposed revisions.
Comment: A letter writing campaign expressed concern
regarding the proposals to the anti-markup provisions,
contending that it would limit the ability of allergists to
provide services on a part-time basis with more than one
group and, in particular, would limit access to allergy
care (including allergy diagnostic tests), to Medicare
beneficiaries in rural or underserved areas. The
commenters urged that our proposals not be implemented.
Response: We have adopted the first proposed
alternative with modification, whereby the anti-markup
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