 
August 5, 1998
Health Care Financing Administration Re: PROPOSED RULE HCFA-1885-P To Whom It May Concern: The Association of American Physicians and Surgeons ("AAPS") hereby submits its comments to proposed rule HCFA-1885-P ("Proposed Rule"). AAPS is a not-for-profit membership organization that represents thousands of physicians in all practices and specialties. It was established in 1943 to preserve the practice of private medicine, and has remained dedicated to the Oath of Hippocrates and protecting the sanctity of the patient-physician relationship. It is incorporated in the State of Indiana and is tax-exempt under Section 501(c)(6) of the Internal Revenue Code. AAPS objects to the Proposed Rule with respect to its elimination of reimbursement for procedure codes for performing intercostal nerve blocks, facet joint blocks and thoracic or lumbar sympathetic blocks when performed in ambulatory surgery centers (procedure codes 64420, 64421, 64442, 64443, 64520, 64622, and 64623). The risks of these procedures include local anesthetic toxicity, seizures, respiratory and cardiac arrest, total spinal anesthesia, pneumothorax, infection, paralysis and death. Proper monitoring and sterile precautions may be impossible in certain office settings, so many physicians decline to perform them there. The effect of the proposed rule will be to deny patients access to beneficial pain control procedures, or limit their access to settings that some physicians consider to be unsafe. §1801. Nothing in this title shall be construed to authorize any Federal officer or employee to exercise any supervision or control over the practice of medicine or the manner in which Medical services are provided, or over the selection, tenure, or compensation of any officer or employee of any institution, agency, or person providing health services; or to exercise any supervision or control over the administration or operation of any such institution, agency, or person. CONCLUSION. AAPS respectfully urges HCFA to rescind the proposed rule so that patients may continue to have access to a beneficial medical procedure. Sincerely,
Jane Orient, M.D.
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