Medicare Program; Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2010
2016-01-14 2016-01-14 2016-01-14 2016-01-13 2016-01-14 2016-01-14 2016-01-14 2016-01-13 2016-01-14
CMS-2009-0058-5087 CMS-2009-0058-5203 CMS-2009-0058-5210 CMS-2009-0058-4682 CMS-2009-0058-5259 CMS-2009-0058-5292 CMS-2009-0058-5260 CMS-2009-0058-4727 CMS-2009-0058-5299
05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00
https://api.regulations.gov/v4/comments/CMS-2009-0058-5087 https://api.regulations.gov/v4/comments/CMS-2009-0058-5203 https://api.regulations.gov/v4/comments/CMS-2009-0058-5210 https://api.regulations.gov/v4/comments/CMS-2009-0058-4682 https://api.regulations.gov/v4/comments/CMS-2009-0058-5259 https://api.regulations.gov/v4/comments/CMS-2009-0058-5292 https://api.regulations.gov/v4/comments/CMS-2009-0058-5260 https://api.regulations.gov/v4/comments/CMS-2009-0058-4727 https://api.regulations.gov/v4/comments/CMS-2009-0058-5299
Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous
Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous
I am writing to offer comments on the proposed rule for the 2010 Physician Fee Schedule.  As a practicing anesthesiologist, I am particularly concerned about the portion of the proposed rule relating to Section 139: Improvements for Medicare AnesthesiaTeaching Programs.In 2008, Congress passed, as part of MIPPA, the Medicare Anesthesiology Teaching Funding Restoration Act to restore full Medicare payment to academic anesthesiology programs.  Before passage of the bill, Medicare payment to our programs had been cut in half each time an attending oversaw two residents on cases that overlapped.  To this end, I am very pleased that the proposed rule appropriately recognizes this statutory change and proposes to pay the full Medicare fee for cases involving a teaching anesthesiologist and one or two residents (that are not concurrent to other cases) or one resident case that is concurrent to another case paid under medical direction payment rules. I strongly believe that CMS made the correct decision for these cases.I further believe that CMS made the correct decision with respect to payment for anesthesia services furnished by a teaching nurse anesthetist with a student nurse anesthetist, as well as the payment policy for an anesthesiologist, or an anesthesiologist and nurse anesthetist jointly, with a student nurse anesthetist. It is encouraging to see that CMS recognizes the significant differences in experience, education and other qualifications between anesthesia residents and student nurse anesthetists.However, I am disappointed that after acknowledging We do not have data on the extent to which anesthesia handoffs occur during resident or other cases, or whether quality of anesthesia care is affected CMS chose to narrowly interpret the law and require that only one individual teaching anesthesiologist be present during all of the key or critical portions of the anesthesia procedure.  Anesthesia handoffs are a common and necessary part of running a quality and efficient operating room, especially in academic settings where the cases are often longer and more complex than in smaller, non-teaching settings, and where medical expertise is often needed to teach a particular skill or to staff a particular case at any given time.  To arbitrarily raise this issue now directly contradicts anesthesiologys nationally recognized patient safety record, as well as the Congressional intent of providing full funding for overlapping cases as they are currently staffed in every academic program in the country.Anesthesiology is proud of its reputation for quality and the recognition it has received for such efforts by the Institute of Medicine and other sources. We achieved this reputation with current practice, not despite it. Handoffs are a normal part of anesthesia care. They allow smooth, seamless and safe treatment of patients.  Prohibiting anesthesia handoffs would have a ripple effect throughout operating rooms by creating staffing problems in hospitals, which would in turn lead to longer wait times and generally compromise safe and efficient patient care.In the final rule please implement the option that was articulated, but not proposed, and permit different anesthesiologists in the same anesthesia group practice to be considered the teaching physician for purposes of being present at the key or critical portions of the anesthesia case.  This will ensure that anesthesiology residency programs receive full Medicare payment for overlapping cases, just as Congress intended.Sincerely,Jonathan Rhodes, M.D. I am writing to offer comments on the proposed rule for the 2010 Physician Fee Schedule.  As a senior anesthesiology resident, I am particularly concerned about the portion of the proposed rule relating to Section 139: Improvements for Medicare Anesthesia Teaching Programs.In 2008, Congress passed, as part of MIPPA, the Medicare Anesthesiology Teaching Funding Restoration Act to restore full Medicare payment to academic anesthesiology programs.  Before passage of the bill, Medicare payment to our programs had been cut in half each time an attending oversaw two residents on cases that overlapped.  To this end, I am very pleased that the proposed rule appropriately recognizes this statutory change and proposes to pay the full Medicare fee for cases involving a teaching anesthesiologist and one or two residents (that are not concurrent to other cases) or one resident case that is concurrent to another case paid under medical direction payment rules. I strongly believe that CMS made the correct decision for these cases.I further believe that CMS made the correct decision with respect to payment for anesthesia services furnished by a teaching nurse anesthetist with a student nurse anesthetist, as well as the payment policy for an anesthesiologist, or an anesthesiologist and nurse anesthetist jointly, with a student nurse anesthetist. It is encouraging to see that CMS recognizes the significant differences in experience, education and other qualifications between anesthesia residents and student nurse anesthetists.However, I am disappointed that after acknowledging We do not have data on the extent to which anesthesia handoffs occur during resident or other cases, or whether quality of anesthesia care is affected CMS chose to narrowly interpret the law and require that only one individual teaching anesthesiologist be present during all of the key or critical portions of the anesthesia procedure.  Anesthesia handoffs are a common and necessary part of running a quality and efficient operating room, especially in academic settings where the cases are often longer and more complex than in smaller, non-teaching settings, and where medical expertise is often needed to teach a particular skill or to staff a particular case at any given time.  To arbitrarily raise this issue now directly contradicts anesthesiologys nationally recognized patient safety record, as well as the Congressional intent of providing full funding for overlapping cases as they are currently staffed in every academic program in the country.Anesthesiology is proud of its reputation for quality and the recognition it has received for such efforts by the Institute of Medicine and other sources. We achieved this reputation with current practice, not despite it. Handoffs are a normal part of anesthesia care. They allow smooth, seamless and safe treatment of patients.  Prohibiting anesthesia handoffs would have a ripple effect throughout operating rooms by creating staffing problems in hospitals, which would in turn lead to longer wait times and generally compromise safe and efficient patient care.In the final rule please implement the option that was articulated, but not proposed, and permit different anesthesiologists in the same anesthesia group practice to be considered the teaching physician for purposes of being present at the key or critical portions of the anesthesia case.  This will ensure that anesthesiology residency programs receive full Medicare payment for overlapping cases, just as Congress intended.Thank you for your time and consideration. I am writing to offer comments on the proposed rule for the 2010 Physician Fee Schedule.  As a practicing anesthesiologist, I am particularly concerned about the portion of the proposed rule relating to Section 139: Improvements for Medicare AnesthesiaTeaching Programs.In 2008, Congress passed, as part of MIPPA, the Medicare Anesthesiology Teaching Funding Restoration Act to restore full Medicare payment to academic anesthesiology programs.  Before passage of the bill, Medicare payment to our programs had been cut in half each time an attending oversaw two residents on cases that overlapped.  To this end, I am very pleased that the proposed rule appropriately recognizes this statutory change and proposes to pay the full Medicare fee for cases involving a teaching anesthesiologist and one or two residents (that are not concurrent to other cases) or one resident case that is concurrent to another case paid under medical direction payment rules. I strongly believe that CMS made the correct decision for these cases.I further believe that CMS made the correct decision with respect to payment for anesthesia services furnished by a teaching nurse anesthetist with a student nurse anesthetist, as well as the payment policy for an anesthesiologist, or an anesthesiologist and nurse anesthetist jointly, with a student nurse anesthetist. It is encouraging to see that CMS recognizes the significant differences in experience, education and other qualifications between anesthesia residents and student nurse anesthetists.However, I am disappointed that after acknowledging We do not have data on the extent to which anesthesia handoffs occur during resident or other cases, or whether quality of anesthesia care is affected CMS chose to narrowly interpret the law and require that only one individual teaching anesthesiologist be present during all of the key or critical portions of the anesthesia procedure.  Anesthesia handoffs are a common and necessary part of running a quality and efficient operating room, especially in academic settings where the cases are often longer and more complex than in smaller, non-teaching settings, and where medical expertise is often needed to teach a particular skill or to staff a particular case at any given time.  To arbitrarily raise this issue now directly contradicts anesthesiologys nationally recognized patient safety record, as well as the Congressional intent of providing full funding for overlapping cases as they are currently staffed in every academic program in the country.Anesthesiology is proud of its reputation for quality and the recognition it has received for such efforts by the Institute of Medicine and other sources. We achieved this reputation with current practice, not despite it. Handoffs are a normal part of anesthesia care. They allow smooth, seamless and safe treatment of patients.  Prohibiting anesthesia handoffs would have a ripple effect throughout operating rooms by creating staffing problems in hospitals, which would in turn lead to longer wait times and generally compromise safe and efficient patient care.In the final rule please implement the option that was articulated, but not proposed, and permit different anesthesiologists in the same anesthesia group practice to be considered the teaching physician for purposes of being present at the key or critical portions of the anesthesia case.  This will ensure that anesthesiology residency programs receive full Medicare payment for overlapping cases, just as Congress intended. I am writing to offer comments on the proposed rule for the 2010 Physician Fee Schedule.  As a practicing anesthesiologist, I am particularly concerned about the portion of the proposed rule relating to Section 139: Improvements for Medicare AnesthesiaTeaching Programs.In 2008, Congress passed, as part of MIPPA, the Medicare Anesthesiology Teaching Funding Restoration Act to restore full Medicare payment to academic anesthesiology programs.  Before passage of the bill, Medicare payment to our programs had been cut in half each time an attending oversaw two residents on cases that overlapped.  To this end, I am very pleased that the proposed rule appropriately recognizes this statutory change and proposes to pay the full Medicare fee for cases involving a teaching anesthesiologist and one or two residents (that are not concurrent to other cases) or one resident case that is concurrent to another case paid under medical direction payment rules. I strongly believe that CMS made the correct decision for these cases.I further believe that CMS made the correct decision with respect to payment for anesthesia services furnished by a teaching nurse anesthetist with a student nurse anesthetist, as well as the payment policy for an anesthesiologist, or an anesthesiologist and nurse anesthetist jointly, with a student nurse anesthetist. It is encouraging to see that CMS recognizes the significant differences in experience, education and other qualifications between anesthesia residents and student nurse anesthetists.However, I am disappointed that after acknowledging We do not have data on the extent to which anesthesia handoffs occur during resident or other cases, or whether quality of anesthesia care is affected CMS chose to narrowly interpret the law and require that only one individual teaching anesthesiologist be present during all of the key or critical portions of the anesthesia procedure.  Anesthesia handoffs are a common and necessary part of running a quality and efficient operating room, especially in academic settings where the cases are often longer and more complex than in smaller, non-teaching settings, and where medical expertise is often needed to teach a particular skill or to staff a particular case at any given time.  To arbitrarily raise this issue now directly contradicts anesthesiologys nationally recognized patient safety record, as well as the Congressional intent of providing full funding for overlapping cases as they are currently staffed in every academic program in the country.Anesthesiology is proud of its reputation for quality and the recognition it has received for such efforts by the Institute of Medicine and other sources. We achieved this reputation with current practice, not despite it. Handoffs are a normal part of anesthesia care. They allow smooth, seamless and safe treatment of patients.  Prohibiting anesthesia handoffs would have a ripple effect throughout operating rooms by creating staffing problems in hospitals, which would in turn lead to longer wait times and generally compromise safe and efficient patient care.In the final rule please implement the option that was articulated, but not proposed, and permit different anesthesiologists in the same anesthesia group practice to be considered the teaching physician for purposes of being present at the key or critical portions of the anesthesia case.  This will ensure that anesthesiology residency programs receive full Medicare payment for overlapping cases, just as Congress intended. I am writing to offer comments on the proposed rule for the 2010 Physician Fee Schedule.  As a practicing anesthesiologist, I am particularly concerned about the portion of the proposed rule relating to Section 139: Improvements for Medicare AnesthesiaTeaching Programs.In 2008, Congress passed, as part of MIPPA, the Medicare Anesthesiology Teaching Funding Restoration Act to restore full Medicare payment to academic anesthesiology programs.  Before passage of the bill, Medicare payment to our programs had been cut in half each time an attending oversaw two residents on cases that overlapped.  To this end, I am very pleased that the proposed rule appropriately recognizes this statutory change and proposes to pay the full Medicare fee for cases involving a teaching anesthesiologist and one or two residents (that are not concurrent to other cases) or one resident case that is concurrent to another case paid under medical direction payment rules. I strongly believe that CMS made the correct decision for these cases.I further believe that CMS made the correct decision with respect to payment for anesthesia services furnished by a teaching nurse anesthetist with a student nurse anesthetist, as well as the payment policy for an anesthesiologist, or an anesthesiologist and nurse anesthetist jointly, with a student nurse anesthetist. It is encouraging to see that CMS recognizes the significant differences in experience, education and other qualifications between anesthesia residents and student nurse anesthetists.However, I am disappointed that after acknowledging We do not have data on the extent to which anesthesia handoffs occur during resident or other cases, or whether quality of anesthesia care is affected CMS chose to narrowly interpret the law and require that only one individual teaching anesthesiologist be present during all of the key or critical portions of the anesthesia procedure.  Anesthesia handoffs are a common and necessary part of running a quality and efficient operating room, especially in academic settings where the cases are often longer and more complex than in smaller, non-teaching settings, and where medical expertise is often needed to teach a particular skill or to staff a particular case at any given time.  To arbitrarily raise this issue now directly contradicts anesthesiologys nationally recognized patient safety record, as well as the Congressional intent of providing full funding for overlapping cases as they are currently staffed in every academic program in the country.Anesthesiology is proud of its reputation for quality and the recognition it has received for such efforts by the Institute of Medicine and other sources. We achieved this reputation with current practice, not despite it. Handoffs are a normal part of anesthesia care. They allow smooth, seamless and safe treatment of patients.  Prohibiting anesthesia handoffs would have a ripple effect throughout operating rooms by creating staffing problems in hospitals, which would in turn lead to longer wait times and generally compromise safe and efficient patient care.In the final rule please implement the option that was articulated, but not proposed, and permit different anesthesiologists in the same anesthesia group practice to be considered the teaching physician for purposes of being present at the key or critical portions of the anesthesia case.  This will ensure that anesthesiology residency programs receive full Medicare payment for overlapping cases, just as Congress intended. I am writing to offer comments on the proposed rule for the 2010 Physician Fee Schedule.  As a practicing anesthesiologist, I am particularly concerned about the portion of the proposed rule relating to Section 139: Improvements for Medicare AnesthesiaTeaching Programs.In 2008, Congress passed, as part of MIPPA, the Medicare Anesthesiology Teaching Funding Restoration Act to restore full Medicare payment to academic anesthesiology programs.  Before passage of the bill, Medicare payment to our programs had been cut in half each time an attending oversaw two residents on cases that overlapped.  To this end, I am very pleased that the proposed rule appropriately recognizes this statutory change and proposes to pay the full Medicare fee for cases involving a teaching anesthesiologist and one or two residents (that are not concurrent to other cases) or one resident case that is concurrent to another case paid under medical direction payment rules. I strongly believe that CMS made the correct decision for these cases.I further believe that CMS made the correct decision with respect to payment for anesthesia services furnished by a teaching nurse anesthetist with a student nurse anesthetist, as well as the payment policy for an anesthesiologist, or an anesthesiologist and nurse anesthetist jointly, with a student nurse anesthetist. It is encouraging to see that CMS recognizes the significant differences in experience, education and other qualifications between anesthesia residents and student nurse anesthetists.However, I am disappointed that after acknowledging We do not have data on the extent to which anesthesia handoffs occur during resident or other cases, or whether quality of anesthesia care is affected CMS chose to narrowly interpret the law and require that only one individual teaching anesthesiologist be present during all of the key or critical portions of the anesthesia procedure.  Anesthesia handoffs are a common and necessary part of running a quality and efficient operating room, especially in academic settings where the cases are often longer and more complex than in smaller, non-teaching settings, and where medical expertise is often needed to teach a particular skill or to staff a particular case at any given time.  To arbitrarily raise this issue now directly contradicts anesthesiologys nationally recognized patient safety record, as well as the Congressional intent of providing full funding for overlapping cases as they are currently staffed in every academic program in the country.Anesthesiology is proud of its reputation for quality and the recognition it has received for such efforts by the Institute of Medicine and other sources. We achieved this reputation with current practice, not despite it. Handoffs are a normal part of anesthesia care. They allow smooth, seamless and safe treatment of patients.  Prohibiting anesthesia handoffs would have a ripple effect throughout operating rooms by creating staffing problems in hospitals, which would in turn lead to longer wait times and generally compromise safe and efficient patient care.In the final rule please implement the option that was articulated, but not proposed, and permit different anesthesiologists in the same anesthesia group practice to be considered the teaching physician for purposes of being present at the key or critical portions of the anesthesia case.  This will ensure that anesthesiology residency programs receive full Medicare payment for overlapping cases, just as Congress intended. To Whom it may concern:I am writing to offer comments on the proposed rule for the 2010 Physician Fee Schedule.  As a practicing anesthesiologist, I am particularly concerned about the portion of the proposed rule relating to Section 139: Improvements for Medicare Anesthesia Teaching Programs.In 2008, Congress passed, as part of MIPPA, the Medicare Anesthesiology Teaching Funding Restoration Act to restore full Medicare payment to academic anesthesiology programs.  Before passage of the bill, Medicare payment to our programs had been cut in half each time an attending oversaw two residents on cases that overlapped.  To this end, I am very pleased that the proposed rule appropriately recognizes this statutory change and proposes to pay the full Medicare fee for cases involving a teaching anesthesiologist and one or two residents (that are not concurrent to other cases) or one resident case that is concurrent to another case paid under medical direction payment rules. I strongly believe that CMS made the correct decision for these cases.I further believe that CMS made the correct decision with respect to payment for anesthesia services furnished by a teaching nurse anesthetist with a student nurse anesthetist, as well as the payment policy for an anesthesiologist, or an anesthesiologist and nurse anesthetist jointly, with a student nurse anesthetist. It is encouraging to see that CMS recognizes the significant differences in experience, education and other qualifications between anesthesia residents and student nurse anesthetists.However, I am disappointed that after acknowledging We do not have data on the extent to which anesthesia handoffs occur during resident or other cases, or whether quality of anesthesia care is affected CMS chose to narrowly interpret the law and require that only one individual teaching anesthesiologist be present during all of the key or critical portions of the anesthesia procedure.  Anesthesia handoffs are a common and necessary part of running a quality and efficient operating room, especially in academic settings where the cases are often longer and more complex than in smaller, non-teaching settings, and where medical expertise is often needed to teach a particular skill or to staff a particular case at any given time.  To arbitrarily raise this issue now directly contradicts anesthesiologys nationally recognized patient safety record, as well as the Congressional intent of providing full funding for overlapping cases as they are currently staffed in every academic program in the country.Anesthesiology is proud of its reputation for quality and the recognition it has received for such efforts by the Institute of Medicine and other sources. We achieved this reputation with current practice, not despite it. Handoffs are a normal part of anesthesia care. They allow smooth, seamless and safe treatment of patients.  Prohibiting anesthesia handoffs would have a ripple effect throughout operating rooms by creating staffing problems in hospitals, which would in turn lead to longer wait times and generally compromise safe and efficient patient care.In the final rule please implement the option that was articulated, but not proposed, and permit different anesthesiologists in the same anesthesia group practice to be considered the teaching physician for purposes of being present at the key or critical portions of the anesthesia case.  This will ensure that anesthesiology residency programs receive full Medicare payment for overlapping cases, just as Congress intended.Thank you very much for your time.Julius Zsohar III, M.D.Dallas, TX I am writing to offer comments on the proposed rule for the 2010 Physician Fee Schedule.  As a practicing anesthesiologist, I am particularly concerned about the portion of the proposed rule relating to Section 139: Improvements for Medicare AnesthesiaTeaching Programs.In 2008, Congress passed, as part of MIPPA, the Medicare Anesthesiology Teaching Funding Restoration Act to restore full Medicare payment to academic anesthesiology programs.  Before passage of the bill, Medicare payment to our programs had been cut in half each time an attending oversaw two residents on cases that overlapped.  To this end, I am very pleased that the proposed rule appropriately recognizes this statutory change and proposes to pay the full Medicare fee for cases involving a teaching anesthesiologist and one or two residents (that are not concurrent to other cases) or one resident case that is concurrent to another case paid under medical direction payment rules. I strongly believe that CMS made the correct decision for these cases.I further believe that CMS made the correct decision with respect to payment for anesthesia services furnished by a teaching nurse anesthetist with a student nurse anesthetist, as well as the payment policy for an anesthesiologist, or an anesthesiologist and nurse anesthetist jointly, with a student nurse anesthetist. It is encouraging to see that CMS recognizes the significant differences in experience, education and other qualifications between anesthesia residents and student nurse anesthetists.However, I am disappointed that after acknowledging We do not have data on the extent to which anesthesia handoffs occur during resident or other cases, or whether quality of anesthesia care is affected CMS chose to narrowly interpret the law and require that only one individual teaching anesthesiologist be present during all of the key or critical portions of the anesthesia procedure.  Anesthesia handoffs are a common and necessary part of running a quality and efficient operating room, especially in academic settings where the cases are often longer and more complex than in smaller, non-teaching settings, and where medical expertise is often needed to teach a particular skill or to staff a particular case at any given time.  To arbitrarily raise this issue now directly contradicts anesthesiologys nationally recognized patient safety record, as well as the Congressional intent of providing full funding for overlapping cases as they are currently staffed in every academic program in the country.Anesthesiology is proud of its reputation for quality and the recognition it has received for such efforts by the Institute of Medicine and other sources. We achieved this reputation with current practice, not despite it. Handoffs are a normal part of anesthesia care. They allow smooth, seamless and safe treatment of patients.  Prohibiting anesthesia handoffs would have a ripple effect throughout operating rooms by creating staffing problems in hospitals, which would in turn lead to longer wait times and generally compromise safe and efficient patient care.In the final rule please implement the option that was articulated, but not proposed, and permit different anesthesiologists in the same anesthesia group practice to be considered the teaching physician for purposes of being present at the key or critical portions of the anesthesia case.  This will ensure that anesthesiology residency programs receive full Medicare payment for overlapping cases, just as Congress intended. I am writing to offer comments on the proposed rule for the 2010 Physician Fee Schedule.  As a practicing anesthesiologist, I am particularly concerned about the portion of the proposed rule relating to Section 139: Improvements for Medicare AnesthesiaTeaching Programs.In 2008, Congress passed, as part of MIPPA, the Medicare Anesthesiology Teaching Funding Restoration Act to restore full Medicare payment to academic anesthesiology programs.  Before passage of the bill, Medicare payment to our programs had been cut in half each time an attending oversaw two residents on cases that overlapped.  To this end, I am very pleased that the proposed rule appropriately recognizes this statutory change and proposes to pay the full Medicare fee for cases involving a teaching anesthesiologist and one or two residents (that are not concurrent to other cases) or one resident case that is concurrent to another case paid under medical direction payment rules. I strongly believe that CMS made the correct decision for these cases.I further believe that CMS made the correct decision with respect to payment for anesthesia services furnished by a teaching nurse anesthetist with a student nurse anesthetist, as well as the payment policy for an anesthesiologist, or an anesthesiologist and nurse anesthetist jointly, with a student nurse anesthetist. It is encouraging to see that CMS recognizes the significant differences in experience, education and other qualifications between anesthesia residents and student nurse anesthetists.However, I am disappointed that after acknowledging We do not have data on the extent to which anesthesia handoffs occur during resident or other cases, or whether quality of anesthesia care is affected CMS chose to narrowly interpret the law and require that only one individual teaching anesthesiologist be present during all of the key or critical portions of the anesthesia procedure.  Anesthesia handoffs are a common and necessary part of running a quality and efficient operating room, especially in academic settings where the cases are often longer and more complex than in smaller, non-teaching settings, and where medical expertise is often needed to teach a particular skill or to staff a particular case at any given time.  To arbitrarily raise this issue now directly contradicts anesthesiologys nationally recognized patient safety record, as well as the Congressional intent of providing full funding for overlapping cases as they are currently staffed in every academic program in the country.Anesthesiology is proud of its reputation for quality and the recognition it has received for such efforts by the Institute of Medicine and other sources. We achieved this reputation with current practice, not despite it. Handoffs are a normal part of anesthesia care. They allow smooth, seamless and safe treatment of patients.  Prohibiting anesthesia handoffs would have a ripple effect throughout operating rooms by creating staffing problems in hospitals, which would in turn lead to longer wait times and generally compromise safe and efficient patient care.In the final rule please implement the option that was articulated, but not proposed, and permit different anesthesiologists in the same anesthesia group practice to be considered the teaching physician for purposes of being present at the key or critical portions of the anesthesia case.  This will ensure that anesthesiology residency programs receive full Medicare payment for overlapping cases, just as Congress intended.