National Coverage Analysis (NCA) View Public Comments

Bariatric Surgery for the Treatment of Morbid Obesity - Facility Certification Requirement

Public Comments

Commenter Comment Information
Bass MD, Thomas Organization: Gulf Coast Bariatrics
Date: 07/27/2013
Comment:
Please do not extend or perpetuate the COE requirement for bariatric surgery. If there were proven benefit to the COE designation, it would have been evident long before the flurry of papers trying to demonstrate such benefit here at the eleventh hour. If the next chapter in healthcare is going to be written within the framework of evidence-based medicine providing wider access to more people while improving efficiency, why would anyone want to prolong a program that has only limited access

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Vigdorchik, Abraham Date: 07/27/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue in order for people to have a second chance to live a viable life. Without the clinic, it would be difficult to reinforce the changes made by the initial surgery. Also, without the clinic, research would be hindered due to lack of patients for the research students to study on, therefore, there would be less and slower

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Phillips, Steve Title: SENIOR DIRECTOR,HealthPolicy&Reimbursemt
Organization: Johnson and Johnson
Date: 07/27/2013
Comment:

July 24, 2013

Louis Jacques, MD
Director, Coverage and Analysis Group
CMS/OCSQ/Coverage and Analysis Group
7500 Security Boulevard, Mail Stop C1-09-06
Baltimore, MD 21244

Cc:
Patrick Conway, M.D.
Director & CMS Chief Medical Officer
Acting Director, Center for Medicare & Medicaid Innovation
Email: Patrick.Conway@cms.hhs.gov

Marilyn Tavenner
Administrator
Centers for Medicare & Medicaid Services
200

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Simpson, Terry Title: Surgeon
Organization: Afffiliated Surgical Associates
Date: 07/27/2013
Comment:
Agree with the decision. The requirement for facility certification has not improved bariatric surgery - and safest hospitals as judged by outside groups, are often not certified. It has created a "monopoly" style network for some and not resulted in better care. It would be better to pay with outcomes as judged in peri-operative as well as multiple years out
LaMasters, Teresa Title: Medical Director Bariatric Surgery
Organization: UnityPoint Health
Date: 07/26/2013
Comment:

I disagree with the proposed change to the NCD going away from the requirement of patients to go to accredited centers. I strongly believe this change will lead to the most vulnerable group of patients experiencing a higher rate of adverse outcomes. This is absolutely a patient safety issue. I have read the material submitted and I believe an area there is an important aspect that may not be fully understood. The Michigan Surgery Collaborative has made great strides in their community

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Walters, Lori Title: Clinical Dietitian
Organization: OSF Surgical Weight Loss Center of Excellence
Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. I have worked in the field of Bariatric Surgery for the last 23 years and have seen great strides made to promote quality standardized care and safety of the weight loss surgery patient. Much of this is due to the accreditation process implemented in this field of care. Facility Certification supports the Integrated Health

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Sudan, Ranjan Date: 07/26/2013
Comment:
Overall the Centers of Excellence program has helped provide a certin level of quality care to all bariatric patients that has helped reduce morbidity and mortality. It has also helped program obtain adequate support from hospitals for bariatric patients that otherwise would not be forthcoming. The data collection associated with being a COE has also helped provide quality and outcomes data that has allowed benchmarking. Having said this, COE has also become become big business as there is a

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Greene, Barry Title: Director Bariatric Surgery Shady Grove Adventist H
Date: 07/26/2013
Comment:

I wholeheartedly support the continued requirement that a hospital be an accredited center of excellence in order to operate on Medicare patients. The consequence of this requirement has implications that extend beyond Bariatric surgery affecting a hospital’s preparedness to care for all overweight patients; a group increasing in numbers yearly. I have been performing bariatric surgery for 12 years. I continue to see patients that have had mismanaged complications from bariatric surgery

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Pecquex, Nicole Title: Director of Bariatric Surgery
Organization: Steward St. Elizabeth's Medical Center
Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision Memo to remove facility certification. CMS Bariatric facility certification must continue to protect the lives of Bariatric patients.
KAKKILAYA, HARISH Title: Chief of surgery
Organization: Memorial Hospital of Salem County, NJ
Date: 07/26/2013
Comment:
I agree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. The COE requirement causes hardship on medicare patients to get bariatric surgery. It prevents patients from getting surgery at their desired location and by the surgeon they trust. The very fact that ASMBS and ACS are planning to simplify the requirement and reduce the volume of surgery required to become COE proves that almost any facility can now become COE, hence proving the fact

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Mitchell, Charles Title: Medical Director, Bariatric and Metabolic Services
Organization: Roper St. Francis Healthcare
Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.”
Johnstone, NP-BC, Denise Date: 07/26/2013
Comment:
I strongly disagree with the proposed CMS Bariatric Facility Certification decision memo to remove facility certification.
Access to quality surgical care & patient safety is best ensured by continuing bariatric facility certification.
Ahmad, Khaled Title: Fellow
Organization: IUCPQ
Date: 07/26/2013
Comment:
want CMS Bariatric Facility Certification to continue.
Moore, Rachel Title: Chief, Section of Metabolic Surgery
Organization: Louisiana State University
Date: 07/26/2013
Comment:
I support facility certification because bariatric patients lose more weight with fewer complications if they have the support of a multidisciplinary team. Without facility certification, hospitals will have no incentive to provide dieticians, nurse coordinators, physical therapy, psychologists, personnel for data collection about outcomes, etc.
Michigan has a unique and probably unreproducible practice environment. Their experience cannot be expected to apply to other states.
Hutter, MD, MPH, FACS, Matthew Title: Director, Codman Center for Clinical Effectiveness
Organization: Massachusetts General Hospital
Date: 07/26/2013
Comment:
I strongly disagree with the CMS proposed decision memo to remove the requirement for facility certification for bariatric surgery. The Accreditation programs have been critical to the development of high quality bariatric surgery care in the United States, and need to continue. I am a bariatric surgeon, and health services researcher. This proposed decision stands to wipe out one of the most effective quality improvement programs in surgical history. The mortality and complication rates

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Crowley, Rondi Title: Bariatric Program Manager
Organization: Methodist Hospital of Sacramento
Date: 07/26/2013
Comment:

I disagree with the CMS decision to drop the need to send Medicare/MediCal patients to a COE facility. We are a COE facility and we work closely with our surgeon's office in preparing patients for surgery, seeing them in the hospital and also following them postoperatively. Our surgeons are one of the few who take Medicare and/or MediCal patients in Northern California so we get patients from sometimes 150+ miles away. This group of patients often present with additonal barriers and

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Barriteau, Jeanese Title: Program Coordinator
Organization: Brookdale Hospital
Date: 07/26/2013
Comment:
I disagree 100% with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. We have to keep up the quality of care out patient population deserve.
Hines, Harrison Organization: Stanford Bariatric Clinic
Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Without certified facilities, quality improvement efforts will be greatly hampered and patient safety will be compromised. The certification has worked from 2006 until now and will continue to work in the future.
Reyes, Steven Title: Owner/Psychologist
Organization: Bariatric Psychological Services/Steven Reyes, EdD
Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. I believe removing the certification will be detrimental to the industry.
Rogan, Daniel Date: 07/26/2013
Comment:

I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

I feel bariatric surgery is critical to best treat and care for Medicare and Medicaid's target populations, and I know that many of these potential patients would suffer as a result removal of certification.
English, Wayne Title: Director
Organization: Bariatric and Metabolic Institute at Marquette General Hospital
Date: 07/26/2013
Comment:

I am conflicted with the CMS proposed decision memo to eliminate COE accredition. On one hand, evidence shows no significant difference in outcomes in a non-COE versus COE programs. Thus, we should not exclude surgeons who can perform bariatric surgery well and achieves good outcomes, but simply cannot meet the volume criteria to qualify as a COE. On the other hand, there appears to be sufficient data showing that quality of care and patient safety has improved significantly after the

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Torno, Michael Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Bariatric surgery is a highly complex procedure and requires hospital resources to make this procedure safe. Removing the certification will expose pts to risks associated with low volume, non-accredited facilities.
Rosas, Ulysses Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Bariatric surgery lives. It not only helps patients lose weight but also changes their lives for the better. Bariatric surgery helps deal with many of the comorbidities associated with obesity such as diabetes and heart disease.
Akkary, Ehab Title: MD FACS FASMBS
Organization: Akkary Center for Weight Management and Surgical Services
Date: 07/26/2013
Comment:
I strongly disagree with the CMS proposal regarding Bariatric COEs. I am the director of bariatric surgery at two hospitals and in my experience, I have seen significant improvement in providing care to bariatric patients while meeting Standardized guidelines and benchmarks. The CMS proposal seems to be a big step backwards that might cause apparent cheaper care but with more adverse outcomes which will eventually put more financial burden on CMS and lead to undesirable clinical outcomes.
Morton, John Title: Chief, Bariatric and Minimally Invasive Surgery
Organization: Stanford University
Date: 07/26/2013
Comment:
Since the CMS NCD supporting accreditation, lives have been saved, complications have been prevented, readmissions have been averted, cost has been lowered and access has been broadened. Without accreditation, long-term data collection will be impaired and quality improvement efforts will be severely impeded. CMS Facility Certification has worked since 2006. Let’s continue our progress. I am most concerned about the removal of the facility requirement in the Medicare patient population who are

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Patel, Sheetal Date: 07/26/2013
Comment:
I agree with doing away with the certification requirement for facilities to perform bariatric surgery. As a fellowship trained bariatric surgeon I have found that centers of excellences haven't always met up to the standards of facilities without this designation that perform bariatric surgery.
This requirement has for a long time now prevented many individuals, who need it the most, from obtaining these life saving procedures. It has been a hindrance to providing equal access of

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Esparza, Ovet Title: Physician Assistant
Organization: Stanford Hospital
Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue
RUEDA, MARISOL Title: surgery scheduler
Organization: Stanford Hospital and Clinics
Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Ahmed, Shushmita Date: 07/26/2013
Comment:
It is very important that the facility certification requirements are continued for bariatric surgery to ensure quality care for our patients.
Sullivan, Patrick Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposal to remove Facility Certification. CMS Bariatric Surgery Facility accreditation improves patient safety and patient outcomes.
Bocchino, Carmella Title: Executive Vice President
Organization: America's Health Insurance Plans
Date: 07/26/2013
Comment:

Thank you for the opportunity to comment on the Centers for Medicare and Medicaid Services’ (CMS’s) Proposed Decision Memo: Bariatric Surgery for the Treatment of Morbid Obesity – Facility Certification Requirement (CAG-002850R3). America’s Health Insurance Plans (AHIP) is the national association for the health insurance industry. Our members provide coverage to more than 200 million Americans, offering a broad range of health insurance products in the commercial market and demonstrating a

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Thompson, Lynne Title: RN, CBN, Clinical Program Director
Organization: ASMBS
Date: 07/26/2013
Comment:

I am writing to state that I strongly disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I am very much in favor on continued CMS Bariatric Facility Certification for the following reasons:

  1. Patient safety is increased. Numerous publications including those by Encinosa in 2009, Nguyen in 2012, Kwon in 2012, Flum in 2011, Dimick in 2013 and Nguyen in 2013 have demonstrated a significant reduction in

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Hanafy, Hanafy Date: 07/26/2013
Comment:

Thank you for the opportunity to contribute my opinion. I am a bariatric surgeon who is allowed by all major insurers to perform bariatric surgery, and is having great results, despite not being in a designated Center of Excellence facility. We are rigorous about the quality of our work. The only patients who cannot benefit from our services are those who are CMS beneficiaries (Medicare)

1. The COE experiment fulfilled its role as an experiment. It entailed a variable degree

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Lau, James Organization: Stanford school of medicine
Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Baker, John Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. We do not need to return to the earlier days of facilities or practices performing BARIATRIC surgery without proper support and processes in place.
Fridman, Abraham Organization: Fairfield County Bariatrics and Surgical Specialists
Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Beekley, Alec Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Andrews, RN BSN, CMSRN, CBN, Ella Title: RN Bariatric Clinical Coordinator
Organization: Methodist Hospital of Southern California
Date: 07/26/2013
Comment:
I am a RN Clinical Coordinator for our Bariatric Surgery Program. I helped our facility obtain and maintain it's certification. I work for the facility I support Facility Certification Requirement. Studies have shown that this improves overall care of our bariatric surgery patients.Requiring facility certification helps upgrade the care we provide to our patients.
Shingleton, Rita Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove facility certification. I want CMS Bariatric Facility Certification to continue.
Meyer, Laurie Date: 07/26/2013
Comment:
As a provider at a Bariatric Surgery Center of Excellence, I feel maintaining this level of certification is of ut most importance. We work very hard to provide the best care to our patients in an effort to help achieve the best possible outcomes. We go above and beyond and are held to a certain level of standards that is essential for optimal patient care. I could not disagree more with the recent CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I

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Villagrana, Marco Organization: The Joint Commission
Date: 07/26/2013
Comment:

July 26, 2013

Louis Jacques, MD
Director, Coverage and Analysis Group
Center for Clinical Standards and Quality
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Mailstop C1 -09-06
Baltimore, MD 21244

Dear Dr. Jacques:

The Joint Commission appreciates the opportunity to provide comments on CMS’ Proposed Decision Memo on Facility Certification for Bariatric Surgery for the Treatment of Morbid Obesity (Facility

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Telem, Dana Date: 07/26/2013
Comment:
I support CMS Bariatric Surgery Facility Certification as it improves access to quality care as well as ensures appropriate hospital support and resources for this patient population. While I am in support of certification, I also feel that certification should encourage facilities to have adequate resources to meet the needs of bariatric patients, rather than creating artificial hurdles that can limit access to care. Currently what constitutes a COE varies between accrediting bodies and is

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dietrick, john Date: 07/26/2013
Comment:

I am a general and bariatric surgeon in Tampa, Florida. I practice exclusively in a hospital that is not a Center of Excellence for bariatric surgery. I am not in favor of Facility Certification Requirement in it's present form or draft form. The reason for my opposition is that there are not outcome measures for this "certification". In fact, numbers of procedures per year for the institution has been the measure that distinguishes those hospitals with, and those without, certification.

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Blackstone, Robin Title: Medical Director
Organization: Scottsdale Healthcare Bariatric Center
Date: 07/26/2013
Comment:

July 26, 2013

Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, Maryland 21244-1850

I would like to express my serious concern regarding the Centers for Medicare and Medicaid (CMS) June 27, 2013 Proposed Decision Memo on Facility Certification for Bariatric Surgery for the Treatment of Morbid Obesity (Facility Certification Requirement CAG-0025OR3). I disagree that the evidence is sufficient to conclude that there is no value to the

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Parker, Marci Title: RD/ bariatric Coordinator
Organization: Louisiana Center for Weight Loss Surgery/ Dr Walter Sartor
Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. We have seen great results with our bariatric surgery patients with low complications due to dedicated staff and facilities.
Isom, Kellene Title: Bariatric Program Manager and Registered Dietitian
Organization: Brigham and Women's Hospital and Brigham and Women's Faulkner
Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Myers, Christopher Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Patient care and safety are improved when performed at a certified facility. Please don't sacrifice patient care and safety in these sick individuals.
Joyner, Kim Title: Bariatric Program Outcomes Manager
Organization: New Hanover Regional Medical Center
Date: 07/26/2013
Comment:
As a Bariatric Program Outcomes Manager,I respectfully ask that you continue to require COE for bariatrics. There may be isolated institutes that provide the same care as COE, but in general, I do not believe this is the case. Prior to our institution's Bariatric COE status, our outcomes were quite poor. Having proper standards has elevated the level of care and the caliper of general surgeons that perform bariatric procedures. Medicare patients tend to require a higher level of expertise

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Sanborn, Chris Title: Director
Organization: Erlanger Metabolic and Bariatric Surgery Center
Date: 07/26/2013
Comment:
The key argument for me is the current lack of access to care for many Medicare patients. Other than that, I generally support the accreditation requirement (based on experience, not the data presented). Is it not possible to require accreditation for Medicare patients but also provide exceptions for patients that are based on a critical mileage and wait time? That may help to continue to provide quality care AND address some of the access problems that the requirement brings about.
Barnes, Marcia Date: 07/26/2013
Comment:
My comment is this, I feel that bariatric surgery should not require that a facility be a center of excellence.
Ponce, Jaime Date: 07/26/2013
Comment:

Louis Jacques, MD
Director, Coverage and Analysis Group
CMS/OCSQ/Coverage and Analysis Group
7500 Security Blvd.
Mailstop C1 -09-06
Baltimore, MD 21244

Re: CAG-00250R3 (National Coverage Analysis (NCA) for Bariatric Surgery for the Treatment of Morbid Obesity- Facility Certification Requirement)

Dear Dr. Jacques,

The American Society for Metabolic and Bariatric Surgery and American College of Surgeons along with all the undersigned

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Frantzides, MD.PhD, FACS, Constantine Title: Director
Organization: Chicago Institute of Minimally Invasive Surgery
Date: 07/26/2013
Comment:
I strongly agree with the CMS Bariatric Facility Certification proposed decision. This certification should be abandoned because it serves no purpose anymore. It should be left to the surgeons and their hospitals to decide if they are capable of providing bariatric services as is the case for any other ailment. I have been in the epicenter of the laparoscopic bariatric revolution since 1995 and I have published extensively (peer-reviewed articles, books, and chapters). There may have been a

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Patel, Rohit Title: Director, Cooper center for Metabolic & Bariatric
Organization: Cooper University Health System
Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Parker, Marguerite Title: Rn,CBN
Organization: Cherokee Nation WW Hastings Hospital
Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed dicision memo to remove facility certification. I want CMS Bariatric Facility Certification to continue.
Rosen, Jeffrey Date: 07/26/2013
Comment:

I believe that we have already been in a time and place when there was no facility certification. No standardization was being done within a single institution. Outcomes and complications were horific and the introduction of the COE for Medicare allowed for patients that in general are higher risk whether older age or disabled to go to places where the surgeons have experience in bariatric surgery and treating complications.

I feel this decision is not based on the previous

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Moorehead, Melodie Title: Clinical Health Psychologist
Organization: Private Consultant
Date: 07/26/2013
Comment:
I have been in the field of providing psychological serices to bariatric surgery patients since 1985. We at ASMBS have worked long and hard to develop safety for delivery of services. To change the policy in question will put people at risk. Thank you for recognizing the value of bariatric surgery and for helping people in need financially afford the surgery. Centers of Excellence is a minimal requirement for safety.
Best,Melodie Moorehead, Ph. D., ABPP
Nadglowski, Joseph Title: President/CEO
Organization: Obesity Action Coalition
Date: 07/26/2013
Comment:

July 26, 2013

Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, Maryland 21244-1850

On behalf of the nearly 50,000 members of the Obesity Action Coalition (OAC), I would like to express our deep concern regarding the Centers for Medicare & Medicaid Services (CMS) June 27, 2013 Proposed Decision Memo on Facility Certification for Bariatric Surgery for the Treatment of Morbid Obesity (Facility Certification Requirement CAG-00250R3). The

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Nguyen, Alex Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Raum, William Title: Bariatric Endocrinologist
Organization: Oregon Weight Loss Surgery
Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. I have 28 years experience treating morbid obesity and its medical complications in multiple surgical practices. It is clear to me that certification forced hospitals and practices to adhere to the best treatment principals and therefore produce the best outcomes.
Fabian, Matthew Title: Bariatric Surgeon
Organization: Sanford health Fargo
Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Partridge, Sheila Title: Sheila Partridge,MD, Associate Chair of Surgery
Organization: Newton-Wellesley Hospital
Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I feel it is irresponsible to base revoking certification requirements based on ONE study and a study in which more than half of the facilities were Certified Centers, others benefiting from the standard excellence of care promoted by COE's and the patients were mostly young and not medicare patients! I want CMS Bariatric Facility Certification to continue because it is safer for

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Nagle, Derek Date: 07/26/2013
Comment:

I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

Nguyen in a 2012 Journal of the American College of Surgeons (JACS) found significant reduction in mortality in accredited centers (0.06% vs. 0.21%). Compared with nonaccredited centers, bariatric surgery performed at accredited centers was also associated with shorter length of stay (mean difference 0.3 days)

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Challener, Monica Title: Bariatric data collector & patient advocate
Organization: Englewood Hospital and Medical Center.
Date: 07/26/2013
Comment:
“I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue for several reasons.
1. improved paient safety in facilities, doctors office and other facilities.
2. continued data collection, for review and improvement of all bariatric procedures for the safety of all patients.
kaniewski, wanda Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
What everyone is forgetting is that because of ASMBS and ACS certifications bariatric surgery has become what it is. 12-15yrs ago the complications were very high, no one wanted to see these patients if they had problems, they had no follow-up, weight loss (lbs) and success rates were lower. Baritric surgery as a

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schrapps, jerome Date: 07/26/2013
Comment:
I stronly oppose eliminating the COE requirement for medicare patients undergoing bariatric surgery. This will allow virtually any general surgeon to do very complex procedures. The ASMBS/ACS COE program assures a level of care that these patients deserve.
Rutland, Sue Title: Bariatric Program Coordinator
Organization: Carolinas Medical Center-NorthEast
Date: 07/26/2013
Comment:
Since the CMS NCD supporting accreditation, lives have been saved, complications have been prevented, readmissions have been averted, cost has been lowered and access has been broadened. Without accreditation, long-term data collection will be impaired and quality improvement efforts will be severely impeded. CMS Facility Certification has worked since 2006. Let's continue our progress. CMC-NorthEast supports CMS Bariatric Facility Certification because: patient safety is increased, is

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Regan, Joseph Date: 07/26/2013
Comment:
We have been involved in the COE status from the beginning thru the SRC and ASMBS. We strongly believe the process has improved our outcomes and safety record. Bariatric surgery is a complex specialty and the scrutiny involved in the COE program has created a safe environment for patients. Programs dedicated to this level of scrutiny and safety will continue to lead the way in the multi-disciplinary care of the bariatric patient.
Herberholz, Patrice Date: 07/26/2013
Comment:
Of course it makes sense that people undergoing this surgery should have it at the best facility possible. There can be life threatening complications from this surgery.
Couch, Ann Title: Bariatric Surgery Coordinator
Organization: Trinty Medical Center
Date: 07/26/2013
Comment:
As a Bariatric nurse [PHI Redacted], I feel that removing the Facility Certification is a bad idea. As it stands now, centers must provide education for both patients and staff to ensure as good a result as possible. Education is one of the biggest hurdles for patients. This isn't a gallbladder operation where a patient has no real lifestyle change to ensure good results. I have spoken with many patients who had bariatric surgery 20+ years ago and didn't get educated and

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Guyton, Lisa Title: Bariatric Center Manager
Organization: St. Mary's of Michigan
Date: 07/26/2013
Comment:
I agree with Medicare's decision to no longer require COE.
Zeni, Tallal Date: 07/26/2013
Comment:
Data shows that centers of excellence are beneficial for improving care for patients undergoing bariatric surgery. Therefore, I would like to continue to see CMS supporting bariatric facility certification.
Marley, Kim Title: Medical Director Bariatric Surgery
Organization: Windber Medical Center
Date: 07/26/2013
Comment:

I strongly disagree with the decision to eliminate the need for facility certification for bariatric surgery. The ASMBS and ACS have made great strides in improving the safety and efficacy of bariatric surgery through the center of excellence programs they have developed. Their actions have pushed hospitals to provide the infrastucture for this improvement in the quality of bariatric care. Some hospitals and surgeons may claim they have done the same without certification but it is my

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Smyth, Tally Date: 07/26/2013
Comment:
I Support CMS Bariatric Surgery Facility Certification Because:
  • Patient Safety is Increased
  • Is Aligned with other Certification Programs
  • Medicare patients are Sicker
  • Access to Quality Care is Increased
  • Integrated Health is Supported
  • Federal Budget Impact is Neutral
Why would we not want to continue to increase patient safety and quality measures?
Stone, Kristy Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Kemmeter, Paul Title: Medical Director Bariatric and Metabolic Surgery
Organization: Mercy Health Saint Mary's Hospital
Date: 07/26/2013
Comment:
I have been a involved in bariatric surgery over the past 15 years, and have witnessed the benefit that bariatric surgery certification has provided to patient care. Prior to certification requirement, mortality rate associated with bariatric surgery was in the range of 2%. After the introduction of certification requirements, mortality rates have decreased to the present level of around 0.1%. This is partly do to the improvements in medical care, but a large portion of this is secondary to

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Batchelor, Leigh Date: 07/26/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.” It comes down to the fact that humans do what is inspected, not what is expected and removing facility certification would put patient safety and outcomes at risk.
Tuma, Esq., Pepin Andrew Title: Director, Regulatory Affairs
Organization: Academy of Nutrition and Dietetics
Date: 07/26/2013
Comment:

July 26, 2013

Louis Jacques, MD
Director, Coverage and Analysis Group
CMS/OCSQ/Coverage and Analysis Group
7500 Security Blvd. Mailstop C1 -09-06
Baltimore, MD 21244

Re: CAG-00250R3 (National Coverage Analysis (NCA) for Bariatric Surgery for the Treatment of Morbid Obesity - Facility Certification Requirement)

Dear Dr. Jacques:

The Academy of Nutrition and Dietetics (the “Academy”) is pleased to comment on the proposed decision

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Peterson, Richard Title: Chief, Bariatric and Metabolic Surgery
Organization: University of Texas Health Science Center San Antonio
Date: 07/25/2013
Comment:
I am writing to endorse and support a continued CMS certified facility requirement. I would continue to strongly encourage that CMS looks at the volume requirements to understand that lower volume centers can have good outcomes, but understand that inherently, those programs with lower volumes that demonstrate good outcomes all share in common that they adhere to the guidelines set forth by COE. While disbanding the requirements for CMS beneficiaries to require their care at a COE may seem

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Snow, Jay Date: 07/25/2013
Comment:
Let's be serious: No study has ever shown that parachutes decrease mortality rates of soldiers who jump from airplanes. If there is one group of patients who benefit from the thought of a COE, it is the medicare patient. Older patients, renal failure patients, and often time disabled patients, the traditional medicare population is the one group of patients who need an experienced surgeon at a high volume center with nearly all service lines available in order to undergo a safe and effective

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Lalor, Peter Title: Medical Director
Organization: Center for Weight Loss Surgery at Wood County Hospital
Date: 07/25/2013
Comment:
Facility certification is vital to the patients under going bariatric surgery. Removing this accreditation requirement is a horrible idea. Certification mandates an accountability for surgeons and hospitals that did not exist prior. It is a major advocacy tool for patients and patient safety at all levels of care. Preparing for certification and adhering to national standards makes every surgeon and hospital better. The future of medicine and surgery is about quality and there is no better

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Quigley, Maureen Title: Clinical Program Director, Bariatric Surgery
Organization: Dartmouth Hitchcock Medical Center
Date: 07/25/2013
Comment:
I recommend that CMS continue the requirement for facility certification/COE designation.
Amberg, Amy Title: Support Group & Group Exercise Coordinator
Organization: Allina Health
Date: 07/25/2013
Comment:
As a member of a multi-disciplinary team in treating morbidly obese patients at our clinic, I am not in favor of dropping the CMS Bariatric Facility Certification. Our hospital team worked very hard for this certification and our patients and their physicians are more confident about the surgical outcomes at our clinic/hospital. Everyone from the emergency department to X-ray and facilities planning are involved in readying our hospital for this credential. A certified program has to prove

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Klosowski, Janice Title: R.N. Bariatric Program Manager
Organization: Aurora Sinai Medical Center
Date: 07/25/2013
Comment:
I am not in support of the proposal to do away with the facility certification requirement for bariatric surgery. The new study that was printed in the journal "Surgical Endoscopy" found that non-accredited bariatric centers had an in-hospital mortality rate that was more than 3 times higher than accredited centers-that is statistically significant. "The risk of dying from stapling bariatric procedures was signficiantly higher at non-accredited facilities even after adjusting for volume."

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Chua, Thomas Title: President
Organization: Wisconsin Bariatrics, SC
Date: 07/25/2013
Comment:

I have been involved with bariatric surgery for 37 years, and have seen bariatric surgery on patients with no structured program and those that are done in bariatric surgery COE. It's comparing night and day. Medicare patients are usually sicker and they best be done in centers with experienced bariatric surgeons and supporting staff, to achieve a safe and successful surgery. COE equates to experience and good results. I believe it is short sighted in eliminating the COE status for CMS

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Pitchford, Timothy Organization: Marshfield Clinic
Date: 07/25/2013
Comment:
I am in support of waiving the requirement of COE for bariatric surgery. I think the intentions are good. However, I have been performing laparoscopic bariatric surgery for 11 years. I have a very low complication rate, excellent outcomes and a support staff. I have not received COE because I do about 85 surgeries a year instead of 125. Recently I was allowed to apply for Surgeon of Excellence because of my excellent outcomes. I am one of the people who is an excellent surgeon with

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Elezian, Jan Title: Director Corporate Compliance
Organization: Scottsdale Healthcare
Date: 07/25/2013
Comment:
Scottsdale Healthcare in Scottsdale Arizona disagrees with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. The Scottsdale Healthcare Bariatric Program has been an American Society of Metabolic and Bariatric Surgery Center of Excellence for more that six years having been awarded that distinction in 2005. The requirements associated with Center of Excellence accreditation have helped to ensure that the specialized services delivered focus on

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Provost, David` Title: MD, Bariatric Surgeon
Organization: Texas Health Physicians Group
Date: 07/25/2013
Comment:

I strongly support continued CMS accreditation of bariatric surgery facilities. Since the implementation of the accreditation programs by the American College of Surgeons and the American Society of Bariatric Surgery, complications and mortality rates following bariatric surgery have been significantly reduced in both the Medicare and non-Medicare populations. This fact is not disputed, even in those publications which have attempted to discredit the certification process.

A major

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Funk, vicki Title: Practice Manager
Organization: BMI Surgery SC
Date: 07/25/2013
Comment:
I am writing to support the bariatric surgery COE designation and process. The Center of Excellence process has clearly improved bariatric surgery. Since its inception, mortality and morbidity from bariatric procedures has steadily decreased to its present nadir. Patient outcomes would not have improved to this degree without the Center of Excellence process. As "A rising tide raises all boats," non-centers of excellence have also benefitted from the COE process. However if CMS removes the COE

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Wagner, MD, Van Organization: Heart Of America Bariatrics, LLC
Date: 07/25/2013
Comment:
I strongly support the continued use of Center Of Excellence designation required for Medicare patients. I have been doing bariatric surgery for 12 years, and I have performed thousands of operations, including laparoscopic gastric bypass. Bariatric surgery is only a tool, and for success a committed team for postoperative care may have a huge positive impact.
Patterson, Emma Title: Medical Director of Bariatric Surgery
Organization: Oregon Weight Loss Surgery
Date: 07/25/2013
Comment:

I am a bariatric surgeon in private practice for 13 years, and I fully support ongoing facility certification for bariatric surgery.

Although I agree that there is not clear evidence that certification of centers per se has improved outcomes, there is also not clear evidence that removing the certification requirement will benefit patients, and there is a risk that outcomes will deteriorate without center certification.

There is very clear evidence for a volume outcome

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Luttrell, Rex Title: MD
Date: 07/25/2013
Comment:
I have operated in non COE centers and hospitals for years and my results are as good as COE facilities. I am not in favor of having to operate out of a COE facility. It clearly keeps many surgeons from being able to provide care for obese patients.
Callery, Charles Date: 07/25/2013
Comment:

I disagree with the plan to allow Medicare patients to have surgery at non Center of Excellence facilities. As a surgeon who has practiced bariatric surgery for 22 years and who has seen the development and implementaion of the COE at two hospital, I can attest to the improvements in care that come with preparing and maintaining COE status. There is NO question that the hospital administration is more responsive to the needs of the bariatric patient when COE designation is at stake.

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anthone, gary Title: Director of Bariatric Surgery
Organization: Nebraska Methodist Health System
Date: 07/25/2013
Comment:
I have been doing bariatric surgery for 22 years and limited my practice to doing only bariatric surgery for the past 15 years. In my opinion, there has been a definite increase in the quality of care and a decrease in complications since the implementation of the COE model for bariatric surgery. I would not want my friends or relatives having bariatric surgery at a non-COE facility or by a non-COE surgeon. Some things in life are intuitive and limiting a complicated procedure to experts in a

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Zitsman, Jeffrey Date: 07/25/2013
Comment:
I strongly oppose any measure to eliminate the certification requirements for bariatric surgery centers. Centers of excellence force institutions to maintain the highest standards of vigilance and care, and any opposition to certifying these centers does not take place in the best interests of patients. In contrast, surgical centers without required certification are likely driven by financial rather than safety considerations, which should be condemned.
Silberschmidt, Mary Title: Unity Hospital Bariatric Center Program manager
Organization: Allina Health
Date: 07/25/2013
Comment:
Respectfully and strongly, I do not support the CMS proposal to eliminate the need for accreditation for facilities doing bariatric surgeries. As a nurse manager working in this field every day, I see the significant safety and care quality benefits patients get from recieving care in an accredited facility. I work with surgeons who practice in an accredited facility and another surgeon who works in a non-accredited facility. I see a big difference in the level of bariatric knowledge between

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White, Toya Organization: Texas Health Presbyterian Dallas
Date: 07/25/2013
Comment:
I disagree with the CMS proposed decision memo to remove Facility Certification/COE for bariatric surgery. As expressed in the released memo, it is a common interest to focus on patient care outcomes; however, without enforced regulations, statistical and quality information for these patients may not be monitored. In addition, Medicare patients are sicker and have increased risk of mortality and morbidity (as referenced by multiple studies) which further necessities a facility that is

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Joyce, Christopher Title: Medical Director
Organization: BMI Surgery, Bariatric and Minimally Invasive Surgery
Date: 07/25/2013
Comment:
I am writing to support the bariatric surgery COE designation and process. The Center of Excellence process has clearly improved bariatric surgery. Since its inception, mortality and morbidity from bariatric procedures has steadily decreased to its present nadir. Patient outcomes would not have improved to this degree without the Center of Excellence process. As "A rising tide raises all boats," non centers of excellence have also benefitted from the COE proccess. However if CMS removes the

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Wenzel, Dawn Title: Certified Bariatric Abstractor
Organization: Palms of Pasadena Hospital
Date: 07/25/2013
Comment:
“I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.”
Backert, Marlene Date: 07/25/2013
Comment:

I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Patients experience a higher success rate with the increase availability of services at a certified facility.

M.Backert

Kaslik, Jessica Date: 07/25/2013
Comment:
I agree with and support the proposed decision by CMS to remove the facility COE requirement. This requirement has limited access to care and continuity of care for patients seeking bariatric surgery procedures. I agree in with this decision after reviewing the research shown with the proposed decision that seems to substantiate it.
Williams, Brandon Date: 07/25/2013
Comment:

Maintaing the highest possible level of safety is crucial in bariatric surgery. Large studies substantiate that mortality rates are significantly less at accredited bariatric centers. Moreover, this finding is reproducible using completely different database information.

I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

Rudlong, Janet Title: Bariatric Nurse Clinician
Organization: Allina Unity Hospital
Date: 07/25/2013
Comment:
I have worked in the field of Bariatric's since 1996. I saw such great patient benefits for safety, outcomes and lower death rates when Center's of Excellence were established. I believe if we allow Bariatric surgical patients go to any surgeon we will have taken a huge step backwards.
Scharf, Keith Title: Loma Linda University Medical Center
Date: 07/24/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Certification aids in patient safety, improved outcomes, and increased access to care.
Chang, Craig Date: 07/24/2013
Comment:

CMS continues with its stupid decisions that lead healthcare in the wrong direction. there is reasonable data to suggest that Medicare patients undergoing bariatric surgery have a death rate that is 4 times higher than non-Medicare patients.

The decision to allow medicare bariatric surgery in non COE facilities defies common sense. it basically allows the highest risk patients to have surgery in the least qualified facilities.

there is also ample evidence that

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Hamilton, Gerald Title: Bariatric Surgeon
Organization: KC Bariatrics
Date: 07/24/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue in the interest of public safety.
Jafari, Mehraneh Date: 07/24/2013
Comment:
Our data regarding the benefits of accreditation presented at Society of American Gastrointestinal and Endoscopic Surgeons, Baltimore, April 19, 2013, entitled 'Volume and Outcome relationship in Bariatric Surgery in the Laparoscopic Era' clearly demonstrates the benefits of accreditation on patient outcomes. Accreditation is associated with lower risk-adjusted mortality. In fact, high volume centers that are not accredited have outcome similar to that of low volume centers. Therefore, we

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Knight, Dorothy Title: Executive Director
Organization: Fayette Physician Network/JV between Uniontown Hospital and UPMC
Date: 07/24/2013
Comment:

I agree with CMS's approach that facilities do not need the COE designation to provide bariatric surgery.

For community hospitals, this can only benefit those individuals who do not have the opportunity to travel to larger institutions where those services can be performed. Seeing a dietician 6 times before surgery can be difficult for patients who don't have access to transportation.

Davis, Pamela Title: Bariatric Program Director
Organization: Centennial Center for the Treatment of Obesity
Date: 07/24/2013
Comment:

As a Certified Bariatric Nurse, as the program director of a comprehensive, high-volume MBS-AQIP [PHI Redacted], I would like to express my profound concern over the Centers for Medicare & Medicaid Services (CMS) June 27, 2013 Proposed Decision Memo on Facility Certification for Bariatric Surgery for the Treatment of Morbid Obesity (Facility Certification Requirement CAG-00250R3). The Memo states that CMS believes “the evidence is sufficient to conclude that continuing the

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Gautreau, Patricia Date: 07/24/2013
Comment:
As the Director of Perioperative Services, I find the certification requirement should be discontinued as being unnecessary. We were not allowed to continue as an ASMBS Center of Excellence strictly due to volume, not for any other reason. Since that time, we have seen absolutely NO change in outcomes for our patients. Our surgeons still maintain their competencies by also performing Bariatric procedures at other facilities. Our nursing, dietary, and pre-op staff continue to take annual

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Flynn, Brian Date: 07/24/2013
Comment:
CMS should continue their COE requirement due to the fact that Medicare patients are demonstrably sicker, and pose an increased risk of post- operative complications. Additionally, patient safety is increased in a COE environment, with shorter LOS, and lower cost.
Respectfully Submitted,
Brian Flynn
Hayes, Angela Title: Managing Editor, Bariatric Times
Organization: Matrix Medical Communications
Date: 07/24/2013
Comment:

I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

So much work has been done to establish accredited bariatric centers. I feel that they DO matter to patients and providers a like. If I were a patient who was going to have any type of surgery, I know I would feel more assurance at an accredited center with an accredited surgeon.

Leger, Andre Date: 07/24/2013
Comment:
I support eliminating COE requirement, it has not been supported by data and this is now mainstream surgery.
Rehnke M.D., Ernest Title: Bariatric Surgon and Medical Director
Organization: Palms of Pasadena Hospital
Date: 07/24/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove faciltiy certification. I want CMS bariatric facility certification to continue.
Jowers, Ronnie Title: Bariatric Service Line Director
Organization: Southside Regional Medical Center
Date: 07/24/2013
Comment:
As I work at a facility that does not have the CMS Bariatric certification, initially I was supportive of the proposed decision. Upon reflection, I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. In this age of ever shrinking reimbursement for healthcare, hospital administrators are constantly looking to cut costs in attempts to gain profit or break even. My concern is that without the certification process designed to uphold

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Kay, Susan Title: Director, Speciality Surgical Services
Organization: Palms of Pasadena Hospital.
Date: 07/24/2013
Comment:
I disagree wtih the CMS Bariatric Facility Certification proposed decision memo to remove facility certification. I want CMS Bariatric Facility certification as I believe it does enhance outcomes and the comprehensive nature of the program.
Dilks, Rebecca Date: 07/24/2013
Comment:
Facility certification is essential for high quality patient care. I strongly support the continuation of CMS Bariatric Facility Certification.
Beach, Ph.D., Barbara Title: Psychologist
Organization: Cherokee Nation
Date: 07/24/2013
Comment:
I support continued certification of facilities offering bariatric surgery. It is evident through research that outcomes improve when certification standards are in place. The integrated health care approach is also proven to improve outcomes.
westmoreland, matthew Title: Chief - Division Minimally Invasive Surgery
Organization: Baylor Univ Med Ctr - Dallas
Date: 07/24/2013
Comment:
Agree completely that COE designation should not be required for bariatric surgery. Studies reveal that there is no difference in outcomes between COE and non-COE facilities. Outcome depends on physician and clinical provider care, not "bricks and mortar". COE designation does not guarantee optimal outcome. Morbidly obese patients are operated on for a variety of other medical conditions throughout the country w/ acceptable outcomes and no COE process is required.
Jackson, Frances Title: Bariatric Program Coordinator
Date: 07/24/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Meyer, Marcy Date: 07/24/2013
Comment:
Our program at West Hills Hospital & Medical Center, West Hills California does NOT support the continuation of the Facility Certification Requirement. Bariatric surgery has now long been established with all the programmatic surrounds that have made it and continue to make it safe and comprehensive. Due to volume (lower number of procedures annually), we are no longer allowed to be certified, but we have continued the high standards still required of a Center of Excellence (as do most

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Flood, Melissa Title: Nurse Practitioner, Certified
Organization: GW Medical Faculty Associates
Date: 07/24/2013
Comment:
I strongly disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Most Medicare patients with obesity have a multitude of other medical conditions. They need very specialized, knowledgable care, & I think COEs are the best place for them to have surgery & continued follow up. Becoming & maintaining a COE is a vigorous process & shows that the surgeon(s), auxillary staff, & facility

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Baron, Lee Date: 07/24/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Lynch, Tricia Title: Bariatric Director
Organization: North Cypress Medical Center
Date: 07/24/2013
Comment:
I want the CMS Bariatric Facility Certification to continue because it allows guidelines to ensure patient safety. If we take this away, then some facilities and physicians will begin to operate on their own behalf. Sad to say, but not everyone is concerned with the well-being of the Bariatric population; some have their own motive or agenda. For those reasons alone, we as an organization for this population are the advocates for our patients. We will

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Ward, Kimberly Date: 07/24/2013
Comment:
"I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue."
Holman, Shelly Title: Bariatric Surgery Program Coordinator
Organization: St. Elizabeth Regional Medical Center Bariatric Surgery Program
Date: 07/24/2013
Comment:
I strongly disagree with the CMS consideration to discontinue the CMS certification for bariatric centers. Standards of care and a structure must be in place in order for programs to provide the highest level of care. It provides a baseline for programs that want to obtain and maintain optimal care and excellent outcomes. With CMS's current certifications for other specialties, I can't understand why they would want to eliminate structure and standards of care to maintain patient outcomes and

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roberts, cindy Date: 07/24/2013
Comment:
I am deeply concerned about the outcomes of bariatric surgical patients who would seek surgical options through a non COE facility. Following the COE requirements in our program has held our program to highest standards of care for patients resulting in best possible outcomes of preparedness of education, surgical intervention, and postoperative care and optimal long term results. The disease of obesity requires the multidisciplinary approach, as evidenced by research and should not be

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Wooldridge, James Date: 07/24/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
McKinney, Patricia Title: RN, BSN, JD, Bariatric Coordinator
Organization: Norman Regional Health System
Date: 07/24/2013
Comment:
I disagree with obviating the requirement for facility certification. Good care of the bariatric patient has a number of elements. To ensure that the patients are provided all that they need, certain standards are necessary. The certification process ensures that facilities abide by certain standards using the best evidence-based practice. Without certification, I fear we will have wide variation in the care provided to these patients and poorer mean outcomes. CMS should continue to

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Lo Menzo, Emanuele Organization: Cleveland Clinic Florida
Date: 07/24/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Facility Certification has been proven to significantly improve outcomes, including decreasing mortality after bariatric surgery.
Reed, Kim Organization: Columbus Regional Hospital
Date: 07/24/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.”
Barnett, Thomas Date: 07/24/2013
Comment:
I am in favor of CMS not requiring a center of excellence certification. I am a surgeon in Dover Delaware. I do bariatric surgery. Because of this certification I have many patients who have been unable to travel the 50 miles each way to get to the nearest "Center of Excellence"--These patients have to travel this distance many, many times preop and post op--and when they have a complication they end up locally in my ER for me to handle--I have excellent results with half the reported

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Machado, Laura Title: Medical Director
Organization: Sacramento Bariatric Medical Associates
Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue
Stapleton, Connie Title: Psychologist
Organization: Mind Body Health Services
Date: 07/23/2013
Comment:
"I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue."
Che, Fred Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue
Huberman, Warren Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Bhoot, MD FACS, Nilesh Title: Bariatric Surgeon
Date: 07/23/2013
Comment:
I agree with the CMS decision of opting out the requirement of center of excellence. This is limiting access to care. If a cardiac or neuro surgeon does not require center of excellent to treat these bariatric patient then why Bariatric surgeon require this. Data has proved no difference in outcome. CMS should mandate fellowship training for bariatric surgeon.
Girod, Wesley Title: General Surgeon/ Director of Bariatric Surgery
Organization: Southern Surgery and Urology
Date: 07/23/2013
Comment:
The Facility Cert. Requiement is obstructive to the care of patients and my office is referring out 6 patients to another physician an hours drive away for the same procedure that I could perform for them. Our outcomes are extremely successful and I would be willing to put our outcomes against any other facility with a center of exellence. Our facility would become a center of exellence if we could perform the same surgery for patients with medicare that I perform on private insurance

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Golden, Ph.D., Lori Title: Clinical Psychologist
Date: 07/23/2013
Comment:
I strongly disagree with the proposed decision to remove Bariatric Facility Certification. Bariatric surgical candidates need ready access to mental health professionals prior to surgery. Surgery is just a tool; a successful result requires behavioral compliance on the part of the patient. If a patient is struggling with behavioral, emotional, or psychiatric issues, they can compromise long-term outcomes. Identifying and addressing such problems prior to surgery is critical. The benefits to

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Ritz, Stephen Title: Licensed Psychologist
Organization: Private Practice
Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Toomari, Nojan Organization: University of California, Irvine
Date: 07/23/2013
Comment:
“I disagree with the CMS proposed decision memo to remove Facility Certification for Bariatric Facility Certification. I want CMS Bariatric Facility Certification to continue.”
Bovee, Vicki Title: Clinical Dietitian
Organization: Western Bariatric Institute
Date: 07/23/2013
Comment:
"I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue."
Cantrell, Laurie Date: 07/23/2013
Comment:
I strongly disagree with the CMS proposal to no longer require Centers of Excellence Accreditation for MCR beneficiaries. I have worked in the field of bariatric surgery for 12 years and have seen the benefits of accreditation.
Do, Kimberly Title: Bariatric Program Coordinator, RN
Organization: St. Bernardine Medical Center
Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. This decision could result in many jobs lost and lack of services for patients
July, Laura Date: 07/23/2013
Comment:

I strongly disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. This appears to be a step backwards and is of great concern. I would like CMS Bariatric Facility Certification to continue.

Laura V July, MD
Co-Medical Director - Allina Health, Unity Hospital Bariatric Program
Wadum, Marilyn Title: Bariatric Dietitian
Organization: St. Elizabeth Regional Medical Center - Bariatric Program
Date: 07/23/2013
Comment:
The preoperative evaluation of the patient seeking bariatric surgery involves multiple important professional disciplines, including nursing, advanced practice providers, surgery, internal medicine, registered dietitians, cardiology and behavioral health professionals. Please do not lower the standards of care which people with obesity to desperately deserve - America is in an obesity crisis. Please keep the standard for bariatric programs to be accredited.
Alfons, Pomp Organization: Weill Cornell Medical Center/New York Presbyterian Hospital
Date: 07/23/2013
Comment:
The requirements for facility certification should be maintained
There is more than adequate data from AHRQ among others (including Flum et al 2011) to support this.
Ertel, Rosemary Date: 07/23/2013
Comment:
For patient support, I believe CMS Bariatric Facility Certification should continue.
Dickerson, Rachel Title: NP
Date: 07/23/2013
Comment:
I disagree with the decision to eliminate the requirement for COE for Bariatric surgery. This allows for the critically necessary standard of care that patients deserve.
Murphy, Kindra Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Armstrong, Christopher Organization: University of California, Irvine
Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Spina, Christina Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision to remove Facility Certification. CMS Bariatric Facility Certification is critical to maintaining safe outcomes for bariatric patients. High volume centers have greater expertise in dealing with sick patients and also have lower complication rates.
Nicholas, Lauren Title: Assistant Professor
Organization: Johns Hopkins University and University of Michigan
Date: 07/23/2013
Comment:

I am a health economist, assistant professor of Health Policy and Management at the Johns Hopkins Bloomberg School of Public Health, and faculty associate at the University of Michigan. Together with surgeon colleagues, I have been researching the intended and unintended consequences of the 2006 National Coverage Decision for bariatric surgery. Our research suggests that Medicare patients would benefit from the proposed discontinuation of the Facility Certification Requirement for

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McMahon, Ross Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. There is new evidence that there are lower mortality rates in certified centers even at similar volumes.
Parrott, Julie Organization: Central Jersey Bariatrics
Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue because:
  • Patient Safety is Increased
  • Is Aligned with other Certification Programs
  • Medicare patients are Sicker
  • Access to Quality Care is Increased
  • Integrated Health is Supported
  • Federal Budget Impact is Neutral
Cummings, Susan Title: Clinical Programs Coordinator
Organization: MGH Weight Center, Massachusetts General Hospital
Date: 07/23/2013
Comment:
“I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.”
Baker, Kristyn Title: 763-236-2044
Organization: Unity Bariatric Center
Date: 07/23/2013
Comment:

I was shocked to read the proposed CMS decision to not require ASMBS SRC standardiation for the Medicare patient. First and foremost, prior to having this standard in place, the death rate following bariatric surgery surged. This was the initiative to instigate a standard in the first place. To take the data from the Michigan consortium and then to determine that they did not have a standard of care and qualification process, is ludicrous. Clearly over $2,000,000 dollars from Blue Cross

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Rivera, Tara Title: RN
Organization: Tristate Bariatrics
Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue because we have worked so hard to create quality center, quality staff and treatment in Bariatric Surgery. In my professional opinion, quality treatment and care of patients would be compromised without centers that are trained specifically in the field.
McBrayer, Molly Title: Bariatric and Metabolic Services Clinical Manager
Organization: Roper Saint Francis Healthcare
Date: 07/23/2013
Comment:
Those patients covered my CMS are predominately older persons that have multiple health issues besides obesity. One would think that CMS would value the extra layer of quality and superior care that is part of earning the COE. I think that it is a shame to put patients covered by Medicare at risk by allowing them to have Bariatric surgery at a facility that has not earned a COE. I would not allow my family or friends to seek care in such a facility and will discourage as many persons that I am

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Spamer, Deborah Title: Bariatric coordinator
Organization: Northside Hospital
Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Reichard, Kirk Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
chin, channing Title: Bariatric Surgeon, M.D.
Organization: Western Bariatric, AMC
Date: 07/23/2013
Comment:

I am a bariatric surgeon in private practice.

I completely disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

Hallowell, Peter Title: Director of Bariatric Surgery
Organization: University of Virginia
Date: 07/23/2013
Comment:
The decision to remove facility certification of bariatric surgery centers by CMS is regrettable. The certification process provides a framework in which bariatric surgery outcomes have improved. Basing this decision on the experience of Michigan is not transferable to the rest of the country and we will likely see a decline in the care of the obese patient. CMS should spend its energies increasing access for patients who could benefit from this life altering therapy.
LaGoo, Deborah Date: 07/23/2013
Comment:
Medicare patients deserve standard of care treatment; requiring that bariatric surgeries be performed at fully accredited centers helps to ensure that this highly vulnerable, higher-risk population receives the highest quality treatment and care available.
Gebhart, Alana Organization: University of California, Irvine Health
Date: 07/23/2013
Comment:
I am a researcher with the Department of Surgery at UC Irvine and I fully support accreditation for bariatric surgery. Since the development of accreditation in 2005, mortality and morbidity in bariatric surgery has significantly declined. Our group recently published data from the University HealthSystem Consortium comparing outcomes between accredited vs non-accredited bariatric centers and found that accredited centers have significantly lower in-hospital mortality compared to

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Schmid, Marietta Title: Director
Organization: Houston Methodist Hospital
Date: 07/23/2013
Comment:
“I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.”
Young, Monica Organization: University of California Irvine Department of Surgery
Date: 07/23/2013
Comment:
As already outlined in the ASMBS email re CMS Bariatric Surgery Facility Certification, numerous studies have be published showing improvements in outcomes, cost and integrated healthcare. Accredited centers for Bariatric Surgery provide more standardized care for high risk Medicare and Medicaid patients. Revoking accreditation would be a step backwards. We should continue supporting CMS Bariatric Surgery Facility Certification.
Skaggs, Judy Title: Director of Mercy Bariatric Center
Organization: Mercy Hospital - Jefferson
Date: 07/23/2013
Comment:
I have worked with the bariatric surgical patient population since 1993. I have watched prejudice, misinformation, lack of education and lack of compassion in healthcare for the morbidly obese patient since my first day in healthcare.
Obesity is now recognized as a disease, why would the CMS group allow the standards of care for this population to diminish?? And it will. In this economy with the changes in healthcare, facilities and physicians without experience or the knowledge of

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Kilgore, P Date: 07/23/2013
Comment:

In years past Bariatric Surgery was considered "cosmetic" to many. It is not cosmetic. Bariatric surgery is a treatment for obesity, a real disease. In the past (prior to COE's)you would hear stories of negative outcomes, i.e. mortalities, complications, etc... Since the implementation of Centers of Excellence we have had hospitals step up to the plate to put the resources into integrated programs to make the program(s) complete and safer for patients seeking this surgical tratment for

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Soto, Flavia Title: MD
Organization: Marquette General Hospital/ Duke Life Point
Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Northup, Joe Date: 07/23/2013
Comment:

I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

If the COE designation is removed, this will be a disaster for patients and lead to severe complications.

Baird, G Title: Bariatric RN Coordinator
Organization: BHCS
Date: 07/23/2013
Comment:
We belong to a large hospital system with some COE facilities and some working to become COE. We all have the same standards of care, our surgeons must be credentialed to perform bariatric surgeries at our hospitals and our care is rated some of the top in the nation. But because our large hospital has so many medicare patients requesting surgeries, we have to send them to the competition in town in order to keep them in an area where they don't have to travel many miles to have surgery and

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Kupchik, Nicole Title: Bariatric Surgery Program Coordinator
Organization: Swedish Medical Center
Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Wilde, Ray Title: Practice Administrator
Organization: Rocky Mountain Associated Physicians
Date: 07/23/2013
Comment:
I have been the Practice Administrator of a Bariatric Surgery group for 6 years. I have seen many occasions where our surgeons end up re-operating on bariatric patients from other surgeons who occasionally do these surgeries. These are specialty operations, and should only be done by those surgeons who are experienced and perform high volumes, rather than just one or two per year. I strongly recommend that a volume requirement remains with the center of excellence.
Braden, Amy Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Allen, Alicia Title: Registered Dietitian, Bariatric Supervisor
Organization: St. Mark's Hospital
Date: 07/23/2013
Comment:

As a facility who has been doing bariatric surgery for over 30 years, with the implementation of certification requirements, it has pushed weight loss surgery programs to excel to a higher level and invest more into the care of patients. It would be concerning if certification was abandoned and patients were brought to surgery and left without the necessary support system to help them succeed with this life change. I support certification that monitors the outcomes, support and education of

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Saddler, Crissi Title: Director of Respiratory Care, Sleep and Bariatrics
Organization: The Bryn Mawr Hospital
Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Allie, Tammy Organization: NYU Medical Center
Date: 07/23/2013
Comment:
I am in favor of continuing the Facility Certification Requirement. It is essential to continue this program. It is increases patient safety and lets all patients know what facility is expert in Bariatric Surgery. It is instrumental in data collection which drives best practices.Medicare patients are sicker and certification will ensure that all education components for staff are met and evidence based research is used to promote the best outcomes. It will be a mistake to discontinue the

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Giaccone, Vincent Date: 07/23/2013
Comment:
In light of 2 recent studies that demonstrate the added safety obtained whenn a facility is accredited, I vehemently oppose your resolution to eliminate COE requirement.
It is cost neutral to all but the facilities involved. Most insurers, other than CMS, require it.
No negatives from requirement, only positives.
LaBrecque, Christine Title: Director
Organization: Lowell General Hospital
Date: 07/23/2013
Comment:
Facilities should be required to continue certification
Schrope, Beth Title: Assistant Professor of Surgery
Organization: Columbia University
Date: 07/23/2013
Comment:
I AGREE with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I believe that the CMS Bariatric Facility Certification was created to supplement the incomes of those involved originally with the SRC as well as others. There seems to be no advantage to COE certification and only appears to increase expenses for already financially constrained providers.
Hinkel, Mindy Title: Bariatric Coordinator
Organization: Advocate Good Samaritan Hospital
Date: 07/23/2013
Comment:
I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
Olbrych, Catherine Title: Bariatric Nurse Specialist
Organization: JFK Medical Center Bariatric Wellness & Surgical Institute
Date: 07/23/2013
Comment:

I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue for the following reasons:

  • Patient Safety is Increased
  • Is Aligned with other Certification Programs
  • Medicare patients are Sicker
  • Access to Quality Care is Increased
  • Integrated Health is Supported
  • Federal Budget Impact is Neutral

    Since the CMS NCD supporting

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  • Matney, Jim Title: CEO & President
    Organization: Colquitt Regional Medical Center
    Date: 07/23/2013
    Comment:

    As CEO & President of Colquitt Regional Medical Center in Moultrie, Georgia, I wish to applaud your proposal in eliminating the certificate of excellence designation for facilities providing bariatric surgical services.
    In Moultrie-Colquitt County, we are a sole community 99-bed hospital with an overall payor mix of about 50% Medicare patients in a population of approximate 46,000.
    The current requirement for COE for Medicare patients have limited our services to patients in need.

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    Banford, Elizabeth Title: Senior Risk Consultant
    Organization: Stevens & Lee
    Date: 07/23/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Since the CMS NCD supporting accreditation, lives have been saved, complications have been prevented, readmissions have been averted, cost has been lowered and access has been broadened. Without accreditation, long-term data collection will be impaired and quality improvement efforts will be severely impeded. CMS Facility

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    Copley, Marsha Date: 07/23/2013
    Comment:
    "I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue."
    Mills, Kristen Organization: St John Weight Loss
    Date: 07/23/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Alston-Hannibal, Tanya Date: 07/23/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Alley, Joshua Organization: Guthrie Clinic
    Date: 07/22/2013
    Comment:

    I believe Bariatric Surgery Facility Certification is important, and should continue. I believe the American Society for Metabolic and Bariatric Surgery, along with the American College of Surgeons, are best entrusted to design a logical certification system. Such a system needs to have real-time, risk-adjusted outcomes reporting, and eventually such data should be publicly available. Transparency is an important element of public trust.

    Joshua B. Alley, MD FACS
    Director

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    Hurd, Jane Title: Bariatric Program Coordinator
    Organization: St Luke's Medical Center- Boise
    Date: 07/22/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision to remove Facility Certification. CMS Bariatric Facility Certification should be continued."
    Massey, Gerald Title: Director of Operations and Bariatric Program
    Organization: BayCare Health System
    Date: 07/22/2013
    Comment:
    On behalf of BayCare Health Sysytem, we express our support for Medicare's decision to remove the COE requirement. This will result in increased access for many patients who are interested in using our bariatric surgical services, but have been unable to due to this COE requirement. Our outcomes our very good with out the COE stamp.
    Fuehrer, Kim Title: Bariatric Coordinator
    Organization: Marshfield Clinic
    Date: 07/22/2013
    Comment:
    I disagree with the proposal to eliminate facility certification for bariatric surgery. Thank you.
    Huffmon, Laura Organization: Clark Memorial Hospital
    Date: 07/22/2013
    Comment:

    I am writing to express my opinion about the requirement for a COE facility for bariatric services. As a bariatric nurse [PHI Redacted] I do not feel it is necessary or beneficial for pts to be required to have their procedures at a COE facility. Our program is small(which hinders us from obtaining a COE certification) However I would put our program up against any COE program. We see our Pts frequently, follow them closely. They can come to our clinic as often as they

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    Britton, Sue Title: Program Director
    Organization: Marquette General Hospital
    Date: 07/22/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. The requirements necessary to obtain certification help to insure that hospitals are providing the institutional support needed for adequate facilities to care for the bariatric population.
    Diede, Lynelle Title: Bariatric Progaram Manager
    Organization: Bariatric Center of the Rockies at Poudre Valley Hospital
    Date: 07/22/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. As much as would like to believe facilities would subject themselves to the added expense and diligence to ensure patient and staff safety, I am realistic and do not believe it would happen without the Facility Certification requirement.
    Scott, Daniel Date: 07/22/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue, as this system of standards has raised the quality and safety of care which our patients recieve. Multiple studies have documented improved outcomes, including 3-fold reduced mortality, at accredited centers.
    Izlar, Janice Date: 07/22/2013
    Comment:

    July 22, 2013

    Louis Jacques, MD
    Director, Coverage and Analysis Group
    Centers for Medicare & Medicaid Services
    Department of Health and Human Services
    7500 Security Boulevard
    Baltimore, MD 21244-8010

    RE: Proposed Decision Memo for Bariatric Surgery for the Treatment of Morbid Obesity-Facility Requirement (CAG-00250R3)

    Dear Dr. Jacques:

    The American Association of Nurse Anesthetists (AANA) welcomes the opportunity to comment

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    Forrester, Glenn Date: 07/22/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Flood, Kathleen Title: Bariatric Program Coordinator
    Organization: Southern Ocean Medical Center
    Date: 07/22/2013
    Comment:
    I disagree with CMS removing the requirement for facilities to be certified for Bariatric surgery. I feel this trivializes the importance of Centers who strive to have standards, policies and protocols for their bariatric patients to have the best outcomes.
    Dougherty, Robert Title: President
    Organization: Matrix Medical Communications
    Date: 07/22/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Rizzo, Susan Title: OP Dietitian and Diabetes Educator
    Organization: Alexian Brothers Medical Center
    Date: 07/22/2013
    Comment:
    As a dietitian and diabetes educator, I work closely with patients utilizing bariatric surgery to successfully manage their weight and improve diabetes control. The certification process requires all members of the team to work together, sharing research and experience assuring a multidisciplinary approach that improves patient care and is cost effective in terms of treatment. As a dietitian I am able to educate and share vital nutrition education with nurses and physicians that helps improve

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    Smith, Brian Title: Chief, General Surgery
    Organization: VA Long Beach Healthcare System
    Date: 07/22/2013
    Comment:

    To Whom It May Concern:

    I disagree wholeheartedly with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I bwlieve CMS Bariatric Facility Certification should continue, and these are some of the most significant reasons:

    1. Patient Safety is Increased
    2. It is Aligned with other Certification Programs
    3. Medicare patients are Sicker
    4. Access to Quality Care is Increased
    5. Integrated Health is

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    Buchwald, Henry Organization: University of Minnesota
    Date: 07/22/2013
    Comment:

    To Whom It May Concern:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove facility certification. Facility certification is valuable and should be continued. At no increased cost to the federal budget, this program has, and should continue, to increase patient safety, improve access to quality care, promote the concepts of integrated health, and continue to remain aligned with other certification programs. Today, we live in a world of

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    Strange, RN, BSN, Sally Title: Bariatric Program Coordinator
    Organization: Hartford Hospital
    Date: 07/22/2013
    Comment:
    "I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue." I believe there is a difference in quality of care and safety with the certified programs. We need to continue to offer the best care for this population.
    Mechanick, Jeffrey Date: 07/22/2013
    Comment:

    Dear Dr. Jaques:

    The American Association of Clinical Endocrinologists (AACE) appreciates the opportunity to provide comment regarding the proposal by CMS to eliminate the designation for bariatric surgery “Centers of Excellence” (COE) [Proposed Decision Memo for Bariatric Surgery for the Treatment of Morbid Obesity - Facility Certification Requirement (CAG-00250R3)]. CMS proposes to remove the COE certification requirement based evidence indicating that continuing the

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    Craggs, Lillian Date: 07/22/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Petrone, Thomas Title: Psychologist
    Organization: Psychological and Counseling Center, Inc - WestPpenn Bariatric C
    Date: 07/22/2013
    Comment:
    I have been a member of the staff of the Bariatric Surgery Center at West Penn Hospital in Pittsburgh for the past 11 years. As the staff Psychologist, I have conducted thousands of Pre-op psychological evaluations. My staff and I have also provided pre and post-operative mental health care for hundreds of patients. I have witnessed the benefit of the facility certification requirement and how it has been a basis of quality care for our staff and patients. I disagree and object to the

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    Williams, Michael Organization: American Association of Clinical Endocrinologists
    Date: 07/22/2013
    Comment:

    Louis Jacques, MD
    Director, Coverage and Analysis Group
    Centers for Medicare and Medicaid Services

    RE: Proposed Decision Memo for Bariatric Surgery for the Treatment of Morbid Obesity - Facility Certification Requirement (CAG-00250R3)

    Dear Dr. Jaques:

    The American Association of Clinical Endocrinologists (AACE) appreciates the opportunity to provide comment regarding the proposal by CMS to eliminate the designation for bariatric surgery “Centers of

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    Klittich, Christine Title: Bariatric Program Coordinator
    Date: 07/21/2013
    Comment:
    As a certified bariatric nurse, I want to verbalize my belief that certification for facilities as centers of excellence should continue. Having gone through the process of certification at 3 different facilities, I know that meeting the standards and requirements to become a COE requires a lot of hard work and commitment from all of the multidisciplinary team. The specialty of Bariatric surgery has come a long way in promoting safety,patient and staff education, long term follow up and

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    Martinez BSN,CBN, Tracy Title: Program Director
    Organization: Wittgrove Bariatrc Center
    Date: 07/21/2013
    Comment:
    I have been a RN in this specialty for over twenty years. I strongly support the accreditation of bariatric surgery programs. In my experience, at five medical facilities, it has been the accreditation that has been the motivator for hospitals to comply with requirements for certification. Too often, medical centers choose finance over optimal care if given the liberty. COE centers have minimal standards that must be achieved from surgical credentialing to specialized staff training.

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    Calzadilla, Marylin Date: 07/21/2013
    Comment:
    “I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.”
    Bauman, Roc Title: Medical Director and Surgeon
    Organization: Carolinas Medical Center NE
    Date: 07/21/2013
    Comment:

    Dear Centers for Medicare and Medicaid Services:

    As a bariatric surgeon of 13 years and one of the first to commit to the concept of a full and dedicated program for the bariatric patient in North Carolina, I’ve seen the consequences of itinerant surgeons, dabbling surgeons, and programs without the commitment and/or the facility to provide the services that these extraordinary patients require. The fallout is poor technical performance, poor outcome, weight regain, complication,

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    Goedert, RN, BSN, Della Title: RN Bariatric Coordinator
    Organization: Exempla Saint Joseph Hospital
    Date: 07/21/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. This is all about patient safety.
    Maier, Dennis Title: MD
    Organization: St Vincent Healthcare
    Date: 07/21/2013
    Comment:
    I agree with allowing Medicare patients to choose where they would like to have their bariatric procedure performed. The medicare patients in our city need to travel at least 230 miles to have surgery, then return home away from their surgeon and follow-up assistance. This is a hardship for our medicare population and limits their access to care. Our "low volume" center has been providing quality outcomes for 10 years. There is no justification and no good data to support limiting coverage to

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    Murphy, Denise Title: MD
    Date: 07/21/2013
    Comment:
    I agree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification and improving access to care for your covered lives.
    Inabnet, William Date: 07/21/2013
    Comment:
    I support the accreditation process for institutions.
    Murr, Michel Date: 07/20/2013
    Comment:

    Dear CMS Official

    I am writing to express my concern about the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I support Facility Certification and request CMS to continue the existing facility certification and Center of Excellence.

    I am a Professor of Surgery, Physiology and Molecular Pharmacology at the University of South Florida. I have practiced bariatric and gastrointestinal surgery since 1995 and have published more than

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    Olsen, Alison Date: 07/19/2013
    Comment:
    "I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue."
    Zundel, Natan Date: 07/19/2013
    Comment:
    I think some form of accreditation is very important to have good Baritric Centers
    Miletics, Maureen Title: Director of Bariatric Services
    Organization: St Luke's University Health Network
    Date: 07/19/2013
    Comment:
    I disagree with CMS decision to suggest that patients should not be required to go to a bariatric center of excellence for their bariatric surgery.
    Arioli, Sandra Date: 07/19/2013
    Comment:
    We need to keep our programs honest. Please reconsider a decision made on only one study.
    Ali, Amjad Title: Director Bariatric Surgery
    Organization: UPMC Hamot Medical Center.
    Date: 07/19/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

    CMC Bariatric Facility Certification has provided several benefits including

  • Patient Safety has Increased
  • The Aligned with other Certification Programs
  • Medicare patients are much sicker
  • Access to Quality Care is Increased
  • Integrated Health is Supported
  • Federal

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  • Schirmer, Bruce Title: Stephen H. Watts Professor of Surgery
    Organization: University of Virginia Health System
    Date: 07/19/2013
    Comment:
    I am writing to strongly oppose the CMS proposal to abandon the requirement for bariatric surgery center accreditation as necessary for centers to perform bariatric surgery for patients who have Medicare or Medicaid insurance. I am a baratric surgeon who has been performing bariatric surgery for 28 years. The typical Medicare or Medicaid patient usually has more severe medical problems, social support limitations, and other factors that make them at higher risk for complications after

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    Eid, George Title: Associate Professor of Surgery
    Organization: University of Pittsburgh
    Date: 07/19/2013
    Comment:
    As quality and good patients' outcome continue to be the driving force of healthcare policies, it is imperative to maintain the requirement of surgeon and facility accreditation for Bariatric Surgery . The need for a well organized infrastructure , facility support and maintenance of a reliable database , has been instrumental in delivering quality Bariatric surgery care to my Medicare patients . I strongly believe that the lack of the accreditation requirements for Bariatric surgery

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    Schmittle, Janice Title: Bariatric Program Coordinator
    Organization: Duke Regional Hospital/Duke Metabolic & Weight Loss Surgery Prog
    Date: 07/19/2013
    Comment:
    The Center of Excellence accreditation shows the facility has completed requirements to provide the safest care possible. The staff undergoes Bariatric Sensitivity Training and safety training to best care for the patient and family. The facility has weight capacity equipment, including BP cuffs as well as OR tables, to meet needs. Multidisciplinary teams are set up, with meetings held to discuss issues. Ths list goes on and on. If the COE is not required, facilities may not be equipped to

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    Belli, Carolyn Title: Patient Service Coordinator, Bariatrics
    Organization: Alexian Brothers Health System
    Date: 07/19/2013
    Comment:
    "I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue."
    Davis, Ruth Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Sienkowski, Monica Title: RN, BSN
    Organization: St. John Providence
    Date: 07/19/2013
    Comment:
    In analyzing the studies, I have concluded that there is conflicting information. Some of the studies support COE and others do not. A few flaws were mentioned by the authors of the studies. One stated that "there was suboptimal statistical power for detecting differences between COE and non COE" Birkmeyer et al.). Another study shows "a 3.5 fold increase in observed in- hospital mortality compared to accredited centers" (Nguyen et al.).
    Therefore at this time, I support continuing

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    Plank, Matthew Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. At my facility there is a multidisciplinary approach to weigh loss surgery. Our team includes dedicated dieticians, therapists, bariatric medicine specialists and bariatric surgeons. Because of our high volume, our other services are also very well versed in post bariatric surgery patients such as emergency department and

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    Zaragoza, June Date: 07/19/2013
    Comment:
    As the coordinator and dietitian for a bariatric program started in 2004 feel the application for certification improved our program, ensuring proper equipment, coverage, support programs, patient outreach, team building for the staff. Simply providing surgery is a disservice to these complex patients who need ongoing contact with a multi-disciplinary team.
    Fraker, Teresa Date: 07/19/2013
    Comment:

    It is extremely important to continue the CMS Bariatric Certification program as it is integral to patient safety, quality & data outcome knowledge.

    The American Society for Metabolic & Bariatric Surgery (ASMBS) serves as the preeminent organization of expertise in this arena, & should be integrally involved in any decisions made in this regard.

    LePort, Peter Organization: Leport
    Date: 07/19/2013
    Comment:
    This proposal to remove Facility Certification will be dangerous to patients in general and specifically to older and Medicare patients. They need the expertise demonstrated by physicians at these facilities. Although many studies have attempted to show effectiveness, none of them have the scientific methods that are required to come out with a good conclusion. To just eliminate the certification without real, in depth conclusions is irresponsible. I disagree with the CMS Bariatric Facility

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    Brient, Bruce Title: surgeon
    Organization: North Florida Regional Medical Center
    Date: 07/19/2013
    Comment:
    I favor continued certification of bariatric centers because hospitals have improved the outcomes of bariatric surgery as a result of this activity.
    DeNamur, Wendy Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. MS Bariatric Facility Certification is extremely important to provide quality, consistent care to our patients-
    Sarwer, David Title: Professor of Psychology
    Organization: Perelman School of Medicine at the University of Pennsylvania
    Date: 07/19/2013
    Comment:

    I am a Professor of Psychology in the Departments of Psychiatry and Surgery at the Perelman School of Medicine at the University of Pennsylvania. Our bariatric program is one of the highest volume programs in the country. Since 1998, I have conducted the preoperative psychological evaluations of our patients and, since 2001, I have had an active program of research (funded by grants from the National Institutes of Health) on the psychosocial and behavioral aspects of bariatric surgery.

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    Bunnell, Sue Title: Bariatric Manager
    Organization: Princeton Baptist Medical Center
    Date: 07/19/2013
    Comment:
    "I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue."
    Thank you, Sue Bunnell
    Hymowitz, Genna Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision to remove Facility Certification. I believe it is imperative that CMS Bariatric Facility Certification to continue to ensure that patients receive optimal pre and post surgical care.
    Flanders, Karen Date: 07/19/2013
    Comment:
    Please accept this comment as a formal expression of my disappointment in the proposed decision for bariatric surgery for the treatment of morbid obesity-facility certification requirement. As a health care provider in bariatric surgery, I have observed the changes that have occurred over the years in health care practice and in health care facilities as a result of the awareness of morbid obesity. Much of this awareness I believe has stemmed from the requirements mandated for center of

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    Burns, Tammi Title: Bariatric Coordinator
    Organization: Scottsdale Healthcare Bariatric Center
    Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Nusbaum, Michael Title: Chief of Bariatric Surgery
    Organization: Morristown Medical Center
    Date: 07/19/2013
    Comment:

    I firmly believe that removing the requirement is a serious mistake. When I performed my first laparoscopic bariatric operation 15 years ago, we lacked significant support from our institution. It rapidly became evident that institutional support was critical to the success of a quality bariatric surgery program. It was only when the center of excellence programs were created that institutional support of the bariatric surgery programs became a requirement. As a result, the center of

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    Restuccia, Nancy Organization: Columbia University Center for Metabolic and Weight Loss Surgery
    Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Sann, Nathaniel Title: Bariatric Program Director and NP
    Organization: Alleghenies Surgical
    Date: 07/19/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. I have been in the field of bariatrics since 2004. I have seen firsthand major positive changes since the development and implementation of the accreditation and facility certification program. First and foremost, patient safety has improved. There have been numerous publications that validate lower complication rates and

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    Forsyth, Judy Title: RN/Clinical Coordinator/Bariatric/Surg. Coordinat.
    Organization: Mercy San Juan Medical Center
    Date: 07/19/2013
    Comment:
    I do not agree with the CMS Bariatric Facility proposed decision to remove Facility Certification. I would like the CMS Bariatric Facility Certification to continue. As a Clinical Coordinator and Bariatric Surgical Coordinator at a Center of Excellence for Bariatric Surgery Medical Center, I feel it is very important for patient safety and also to provide these patients with quality care. Often Medicare patients have many co-morbidities and are sicker than other patients, and they need

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    Grant, Rebecca Title: Bariatric Program Coordinator
    Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. Facility certification requires a commitment on the part of the surgeon and facility that improves patient safety. I do believe that the criteria for certification should be based on quality outcomes though, and not solely on surgical volumes. The primary motivator for CMS should be to promote patient safety. The certification process is an important factor in this.
    Szomstein, Samuel Title: associate Director Bariatric Metabolic Institute
    Organization: Cleveland Clinic Foundation
    Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. I Support CMS Bariatric Surgery Facility Certification because Patient Safety is increased, Access to Quality Care is increased and Federal Budget Impact is Neutral. We facility certification we can provide the best possible care to our Medicare population.
    Lawrence, Lori Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove facility certification. I want Bariatric facility certification to continue to provide the best care for our patients with their surgical treatment options for morbid obesity.
    dennehy, denise Title: RDN, CDE
    Organization: Hawasli & Associates
    Date: 07/19/2013
    Comment:

    I feel a facility certification is important-obese patients are not just having surgery to loose weight-they need nutritional support and guidance as they prepare and recover from their procedure.

    Without this requirement for standard surgeons will do surgery and the patient will not be supported as they move through the weight loss process.
    Johnston, Geri Date: 07/19/2013
    Comment:
    I strongly disagree with the CMS proposed decision to remove the requirement for facility certification. Due to facility certification, patient safety and long-term success of this population has dramatically improved. Continuing this requirement for this population is crucial to continue and maintain the gains we have achieved.
    Hilgendorf, William Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Castro, Adiana Title: Clinical Registered Dietitian
    Organization: Weill Cornell Medical College
    Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Registered Dietitians are vital to the success of bariatric patients. If the facility certification were removed that could endanger access for patients to dietitians. That would severely impact the health outcomes of the bariatric patient. In the end, isn't the point to make them healthier?
    Resurreccion, Clara Date: 07/19/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

    Patient has the right to be informed of the quality of their facility.

    several studies clearly shows that patient safety is increased with accreditaion.
    Bishop, Bill Title: VP Business Development
    Organization: Obesity Prevention, Policy and Management
    Date: 07/19/2013
    Comment:

    Support CMS Bariatric Surgery Facility Certification!

    Since the CMS NCD supporting accreditation, lives have been saved, complications have been prevented, readmissions have been averted, cost has been lowered and access has been broadened. Without accreditation, long-term data collection will be impaired and quality improvement efforts will be severely impeded. CMS Facility Certification has worked since 2006. Let’s continue our progress.

    We Support CMS Bariatric Surgery

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    MacColl, Colin Title: Director Bariatric Surgery
    Organization: PeaceHealth
    Date: 07/19/2013
    Comment:
    I completely disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Medicare patients are our sickest patients and thus require the integrated health systems that Certification ensures. It makes no sense whatsoever for facilities and surgeons to undertake these high risk surgeries then transfer the complications to centers that have the original expertise to deal with them. It

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    Dillawn, Patrick Title: Staff Surgeon
    Organization: Seton Medical Center Williamson, Round Rock, Texas
    Date: 07/19/2013
    Comment:
    I am a general and bariatric surgeon in Austin, Texas and a fellow, in good standing, of the ASBMS, and have personally done over 500 bariatric operations with excellent results. While I do believe that experience is an important factor in my work, I do not agree with "Center of Excellence" requirements(or rather, restrictions). I believe that the restrictions are motivated by a desire to prevent competition rather than promote good patient care. COE programs for bariatric surgery (and

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    Brengman, Matthew Title: Chair, Insurance Committe
    Organization: American Society of Metabolic and Bariatric Surgery
    Date: 07/19/2013
    Comment:
    Facility accreditation has resulted in a culture of quality and accountability the has benefited our Bariatric patients. The requirement also results in a financial commitment to quality care and equipment from the facilities that might not otherwise be available in our current cost reduction environment. I support facility accreditation
    Jones, Daniel Title: Professor of Surgery
    Organization: Harvard Medical School
    Date: 07/19/2013
    Comment:
    In 2005 most of the Bariatric Programs became ACS accredited throughout the state of Massachusetts. According to the Department of Public Health annual mortality figures, this closely correlated with dramatic decrease in death after weight loss operations.
    Its common sense that the accredition requirements for proper facilities, personnel and clinical pathways contributed to improves patient outcomes. Without strict guidelines and oversight, hospitals and surgery centers may revert back

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    Dobruskin, Lisa Title: MD FACS
    Organization: Minimally Invasive Surgery Associates of New Jersey, LLC
    Date: 07/19/2013
    Comment:
    I am a bariatric surgeon who operates at several hospitals that have the COE designation. I have also been involved in several COE certifications and re-certifications. I completely agree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I believe that CMS Bariatric Facility Certification should be eliminated as it does not improve patient safety or outcomes, but rather results in increased bureaucracy and cost.
    wegner, robert Date: 07/19/2013
    Comment:
    The continuation of facility certification is absolutely necessary to provide patients with the highest standards of care. KEEP IT!!!!!!!!!!
    El-Hayek, Kevin Date: 07/19/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

    I Support CMS Bariatric Surgery Facility Certification Because:

    Patient Safety is Increased
    Is Aligned with other Certification Programs
    Medicare patients are Sicker
    Access to Quality Care is Increased
    Integrated Health is Supported
    Federal Budget Impact is Neutral
    Lange, Melinda Title: Program Coordinator
    Organization: OSF Saint Francis Medial Center
    Date: 07/19/2013
    Comment:

    To whom it may concern,

    The decision to continue Bariatric Surgery Center of Excellence is necessary in promotion of measurable outcomes, decrease mortality, improved obesity management, and increased quality of life. Our bariatric program has worked for fifteen years to overcome a stigma regarding the mortality rate with bariatric surgery. The medical physicians of our area were trained during the pioneering of bariatric surgery with high mortality and complication rates. The

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    Hoffman, Marcie Title: Director of Contact Center Services
    Organization: Obesity Prevention, Policy & Management, LLC
    Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. This is important in order to increase patient safety, improve access to quality care, and keep bariatrics aligned with other certification programs. I am very concerned that Medicare patients who are often sicker will not receive the level of care they need if facility certification is discontinued.
    Marchesini, Joao Batista Organization: Clinica Marchesini
    Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue
    Smith, Kathleen Date: 07/19/2013
    Comment:
    I support facility COE certifiction.The effort and focus on insuring the evidenced-based standards for metabolic & bariatic surgery help insure the highest quality of care & services for our patients.
    Wehseler, Jill Title: Bariatric Coordinator
    Organization: Cuyuna Regional Medical Center
    Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Rehnke, M.D., Ernest Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Taking away the certification will be detrimental to the standards of the hospital's performing bariatric surgeries and reduce the quality of care. This will greatly effect the outcome of the patient's health.
    Reavis, Kevin Title: Bariatric Surgeon
    Organization: Legacy Weight & Diabetes Institute
    Date: 07/19/2013
    Comment:
    I strongly support ongoing certification of bariatric centers for the surgical treatment of obesity and related metabolic diseases.
    Crowley, Nina Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Faulkenberry, M.D., Tim Title: Partner
    Organization: Southwest Bariatric Surgeons
    Date: 07/19/2013
    Comment:
    I disagree with the CMS Bariatric Facility proposed decision memo to remove facility certification. I respect Dr. Birkmeyer's work but in Michigan's unique circumstance, the Collaborative in effect created a state-wide "Center of Excellence". For most of the rest of the country, the programs that take care of these sicker, more debilitated, patients are better equipped for providing surgery with good outcomes because of COE requirements. I support continuing certification requirements for

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    Kozar, Mark Date: 07/18/2013
    Comment:
    I support the continuation of requirement of certification for facilities performing Bariatric surgery on Medicare patients. There is clear benefit to patients.
    Cunningham, M.D., Carson Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Medicare patients are older, sicker, and higher risk surgical candidates. Their cases should be done in facilities which demonstrate a commitment to quality and safety - a center of excellence.
    Malhotra, Sandeep Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Russo, Michael Title: General Surgeon
    Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Bajwa, Kulvinder Title: assitant professor of surgery
    Organization: university of texas health science center at hosuton
    Date: 07/18/2013
    Comment:
    I think there is a role for Facility certification requirement for the treatment of morbid obesity or as a part of a consortium of hospitals that maintains a collaborative certification focused on quality and good outcomes
    Fermelia, Richard A. Title: Bariatric Medical Director and surgeon
    Organization: American Society for Metabolic and Bariatric Surgery
    Date: 07/18/2013
    Comment:

    I Support CMS Bariatric Surgery Facility Certification!

    Bariatric surgery is a specialty and ordinary general surgeons should not casually do these operations. It is much more that just procedures. These patients need the insight, knowledge and expertise of surgeons dedicated to bariatric surgical care.

    The literature supports the centers of excellence as a way to identify surgeons and centers that have dedicated themselves to doing bariatric surgery practice according

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    Tamura, Benjamin Title: Internal Medicine
    Organization: Kaiser Permanente Hawaii.
    Date: 07/18/2013
    Comment:

    I work in Honolulu Hawaii with an HMO that recently got certified by the ACS/ASMBC COE/MBSAQIP for both Inpatient and Outpatient.

    On behalf of our program, we support CMS Bariatric Surgery Facility Certification because it made us better. In preparation we reviewed ourselves like we otherwise never would have. We made changes prior to the submission and site visit. We didn’t shoot for a score, we wanted to be excellent in every category.

    I'll leave it to other

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    Brethauer, Stacy Title: Surgeon, Bariatric and Metabolic Institute
    Organization: Cleveland Clinic
    Date: 07/18/2013
    Comment:

    This comment is written in strong support of continuing the accreditation requirement for CMS beneficiaries undergoing bariatric surgery.

    CMS has stated that the evidence is sufficient to conclude that continuing the requirement for certification for bariatric surgery facilities would not improve health outcomes for Medicare beneficiaries. The current evidence simply does not support that conclusion. In fact, it is clear from the evidence that removing the requirement for

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    Rajajoshiwala, Presh Date: 07/18/2013
    Comment:
    I am in agreement with CMS decision to abandon COE certification requirement. It has not demonstrated benefits promised and is an obstacle to providing necessary care in many communities.
    Wohlgemuth, Stephen Title: Medical Director
    Organization: Sentara Comprehensive Weight Loss Solutions
    Date: 07/18/2013
    Comment:

    I Support CMS Bariatric Surgery Facility Certification Because:

    * Patient Safety is Increased
    * Is Aligned with other Certification Programs
    * Medicare patients are Sicker
    * Access to Quality Care is Increased
    * Integrated Health is Supported
    * Federal Budget Impact is Neutral

    Patient Safety
    Since the implementation of the original 2006 National Coverage Determination for Bariatric Surgery, we have witnessed an

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    Mattar, Samer Title: Professor of Surgery
    Organization: Indiana University
    Date: 07/18/2013
    Comment:
    As a bariatric surgeon who has been practising this specialty for 10 years,I have witnessed the evolution of this profession from a rather infrequent operation that was occasionally performed by isolated general or trauma surgeons to a flourishing multispecialty discipline that has established new standards for patient safety, clinical outcomes that include multiple diseases, increased quality of life, extended life expectancy, and created an explosion of research material that has formidably

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    Birkmeyer, John Date: 07/18/2013
    Comment:

    In his public comment, Dr. Harvey Sugerman, a senior ASMBS leader, suggests that Justin Dimick and I were financially motivated in requesting that CMS reconsider the COE requirements, a serious but unfair accusation. As stated, we are co-founders of ArborMetrix, a database software company that provides support to the Michigan Bariatric Surgical Collaborative on a pro bono basis. The company has had no other involvement in the field of bariatric surgery and has no financial interest in

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    Halpin, Valerie Title: Bariatric Surgeon
    Organization: Legacy Weight and Diabetes Institute
    Date: 07/18/2013
    Comment:
    I Support CMS Bariatric Surgery Facility Certification Because:
  • Patient Safety is Increased
  • Medicare patients are Sicker
  • Access to Quality Care is Increased
  • Integrated Health is Supported
  • Federal Budget Impact is Neutral

    In my 10 years as a bariatric surgeon I have seen outcomes improve greatly. I believe part of that improvement is directly related to bariatric surgery centers of excellence.

  • Gadaleta, Dominick Date: 07/18/2013
    Comment:

    Since the CMS NCD supporting accreditation, lives have been saved, complications have been prevented, readmissions have been averted, cost has been lowered and access has been broadened. Without accreditation, long-term data collection will be impaired and quality improvement efforts will be severely impeded. CMS Facility Certification has worked since 2006. Let’s continue our progress.

    We Support CMS Bariatric Surgery Facility Certification Because:
  • Patient Safety is

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  • Clements, Ronald Title: Professor of Surgery
    Organization: Vanderbilt University
    Date: 07/18/2013
    Comment:
    I support CMS Bariatric Surgery Facility Certification because patient safety is increased, is aligned with other certification programs, Medicare patients are sicker, access to quality care is increased, integrated health is supported and the Federal budget impact is neutral.
    Bilof, Michael Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. As a Board certified surgeon who has been certified as a Center of Excellence I understand the commitment (both at the institutional and individual surgeon levels) it takes to achieve and maintain this level of excellence. This clearly benefits patient outcomes and safety.
    LaBonte, Lacey Date: 07/18/2013
    Comment:
    I agree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I do not think the CMS Bariatric Facility Certification is necessary and I know that it limits access to care for a lot of people who would benefit from bariatric surgery.
    Redd MD, Myron Date: 07/18/2013
    Comment:
    I agree with the CMS decision to remove facility certification. The COE causes a hardship for my patients,or potential patients. Causing them to have to travel excessive distances for surgery and follow up. This is a good decision in light of the evidence the COE has not improved quality or access.
    fowler, steven Organization: MD
    Date: 07/18/2013
    Comment:
    COE certification has pushed my hospital to invest heavily in proper equipment, training, and personnel. This has been a critical factor in improving our safety and outcomes. I support COE requirement.
    West-Smith, PhD, LCSW, Lisa Title: Executive Director of Bariatric Services
    Organization: Georgetown Community Hospital/Bariatric Services
    Date: 07/18/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

    Since the CMS NCD supporting accreditation, lives have been saved, complications have been prevented, readmissions have been averted, cost has been lowered and access has been broadened. Without accreditation, long-term data collection will be impaired and quality improvement efforts will be severely impeded. CMS

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    Flater, Kris Title: Bariatric Surgery Coodinator
    Organization: Mercy Medical Center Des Moines
    Date: 07/18/2013
    Comment:
    I feel that the center of excellence designation is a very important aspect of bariatric surgery. It not only indicates hospital excellence, but program excellence. Bariatric surgery is a very complex process requiring multidisciplinary involvment and interaction. Patient success relies on continuing education and involvement in a well rounded bariatric program.
    Chorney-Wilson, MSN, RN, CBN, Jessica Date: 07/18/2013
    Comment:
    Facility certification is a way of identifying programs that have gone and continue to go above and beyond in an effort to provide excellence in care for patients suffering from the disease of obesity. Taking the requirement for certification away can lead to laxity in ensuring that staff caring for the patient is adequately trained on an ongoing basis and that that training is congruent with evidence-based medicine.
    Goova, Mouza T Title: Bariatric/General surgeon
    Organization: LewisGale Physicians
    Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Tempes, Rebecca Title: Lead Technologist, Nuclear Medicine
    Organization: Florida Hospital, Kissimmee
    Date: 07/18/2013
    Comment:
    I am surprised you are considering doing away with the facility certification. I tell everyone who asks me to make sure the place they go to carries this distinction. I feel it's very important. However, I do think there should be some way a smaller facility can obtain this. I know they don't do as many procedures per year as what's required.
    R. Tempes, RT(N), CNMT, RN, BSN
    Torquati, Alfonso Title: Director Duke University Center for Bariatric Surg
    Organization: Duke University
    Date: 07/18/2013
    Comment:
    The CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification will have severe consequences for health needs of our obese patients. This decision will allow bariatric surgery procedures in centers with no or limited experience. This will lead to higher complication rates and higher cost for our government.I want CMS Bariatric Facility Certification to continue.
    Wilson, Patricia Organization: Houston Methodist Hospital
    Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Rifai MD, Tom Title: Medical Director, Metabolic Nutrition & Weight Mgt
    Organization: St Joseph Mercy Oakland
    Date: 07/18/2013
    Comment:

    I am in total support of dropping COE criteria for Medicare coverage. It has been an overall, even if well intended, burden for the clinical care of my patients. We now know that there is, if anything, evidence against COE as a tool or designation is counterproductive (JAMA - Michigan Bariatric Collaborative). In light of this, I urge the discontinuation of requirement of COE for bariatric surgery in Medicare patients

    Highest Regards
    Tom Rifai MD
    St Joseph Mercy

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    Xiao, Nianzhou Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Goodnight, Travis Date: 07/18/2013
    Comment:

    I'm in complete agreement with CMS's decision.

    I'm an ASMBS member and have still thought that requirements for an expensive and unnecessary certification were burdensome to many facilities. Although our facility has currently undergone all requirements to be certified by the ASMBS, we have never thought it should be a necessary REQUIREMENT by CMS and was just limiting access to care to Medicare and Medicaid patients who often had to travel 150miles to a certified center. We

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    Paya, Mahbod Title: bariatric surgeon
    Date: 07/18/2013
    Comment:
    I agree that the evidence is sufficient to conclude that continuing the requirement for certification for bariatric surgery facilities would not improve health outcomes for Medicare beneficiaries. I strongly believe that we should remove this certification requirement. I also think surgeons who perform these operations should all be fellowship trained in laparoscopic/bariatrics.
    Grover, Brandon Title: General/Bariatric Surgeon
    Organization: Gundersen Health System
    Date: 07/18/2013
    Comment:
    I disagree with the CMS decision to remove bariatric faculty certification. Many published studies have shown improvement in patient outcomes and decrease in mortality in the recent era where certification has been required. The previous bariatric volume requirement may not be an accurate reflection of patient outcomes, but as a bariatric surgeon, I strongly feel there is a significant benefit to the patients we operate on to require certification.
    Rodriguez, Dawn Date: 07/18/2013
    Comment:
    I agree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification.
    Lin, Edward Date: 07/18/2013
    Comment:

    Abandoning CMS Facility Certification is only good for surgeons who wish to perform bariatric surgery but do not have significant facility infrastructure.

    However, abandoning CMS Facility Certification will create greater variations in practice standards, which is not good for patients. Imagine if individual airlines form their own policies. It would be disastrous.

    Montgomery, Wendy Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Small, Theodore Title: Medical Director, Bariatrics
    Organization: Morton Plant Mease Hospitals-Baycare
    Date: 07/18/2013
    Comment:
    I am the medical director for Morton Plant Mease Bariatric program in Dunedin, FL. I am in agreement with the CMS proposal. I feel that any facility that has good outcomes in performing bariatric cases regardless of COE status should be allowed to offer surgery to Medicare/Medicaid patients seeking such surgery.
    BRIDGETT, KEISHA Title: Referral Cooridinator for Bariatric Surgery
    Organization: ECU Physicians
    Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification, I want it to continue because it:
    Increases patient safety
    Integrated health is supported
    Is Aligned with other cetification programs
    East, Jill Title: Bariatric Program Coordinator
    Organization: Community Bariatric Surgeons
    Date: 07/18/2013
    Comment:
    As a large volume bariatric center's Bariatric Coordinator, I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Nimeri, Abdelrahman Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue especially with the new joined program between ACS and ASAMBS MBSAQIP
    Oakley, Chris Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposal decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Santos, Ana Title: MD
    Date: 07/18/2013
    Comment:
    I Support CMS Bariatric Surgery Facility Certification Because:
    Patient Safety is Increased
    Is Aligned with other Certification Programs
    Medicare patients are Sicker
    Access to Quality Care is Increased
    Integrated Health is Supported
    Federal Budget Impact is Neutral
    McLearen, Angie Title: RN, BSN, CBN Clinical Coordinator
    Organization: Mercy Health
    Date: 07/18/2013
    Comment:
    I am a nurse at a hospital with a center of excellence designation. I have personally seen the positive changes that this has made. The impact on patient care and patient experience is evident. I STRONGLY support bariatric surgery facility certification.
    Sell, Tami Title: Quality Specialist
    Organization: Stanford Hospital and Clinics
    Date: 07/18/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

    Facility Certification saves lives, and it is good for all facitlities to have the same standards of safe and high quality care.

    Redmon, katherine Title: Physician Assistant Certified
    Organization: Virginia Mason Medical Center
    Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue
    McKenzie, RN, CBN, Terry Title: Bariatric Coordinator
    Organization: Center for Obesity Surgery & Treatment
    Date: 07/18/2013
    Comment:
    We Support CMS Bariatric Surgery Facility Certification Because:
  • Patient Safety is Increased
  • Is Aligned with other Certification Programs
  • Medicare patients are Sicker
  • Access to Quality Care is Increased
  • Integrated Health is Supported
  • Federal Budget Impact is Neutral
  • Pories, Walter Title: MD, Professor of Surgery
    Organization: East Carolina University
    Date: 07/18/2013
    Comment:
    The loss of the certification requirement is a serious step backwards. In 2000 - 2004, before COE's were developed for bariatric surgery, the US experienced high mortality rates, high complication rates, poor outcomes and high expenditures due to a failure of quality control. The COE's reduced mortality to 0.3%, the same as routine cholecystectomy,complications and cost. This is a very bad move.
    Hines, Danielle Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    - Medicare patient's are sicker
    - Patient Safety has Increased
    - Quality Care has increased
    Wittgrove, Alan Date: 07/18/2013
    Comment:
    I am a bariatric surgeon and I have been practicing for over 30 years. I have seen unrestricted days of bariatric surgery and I helped develop certification because I steadfastly believe it is in the patient's best interest.I am certainly not looking for more regulation just for the sake of having more work to do but this improves patient outcomes. One or two "studies" may be written to look otherwise but the real-world experience is that certifying facilities (coupled with surgeon

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    Marten, Dena Title: RN
    Date: 07/18/2013
    Comment:
    I agree with the proposed decision to remove facility certification. Our facility provides quality care with supporting data and excellent outcomes. Yet ASMBS will not certify our program due to their imposed volume criteria and their seemingly self-serving & labor-intensive data submission requirements.
    Kothari, Shanu Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue if done with best practice and best evidence and is outcome based and not volume based
    Ben-Meir, Aviv Title: Medical Director, Bariatric Surgery Center
    Organization: Lake Health
    Date: 07/18/2013
    Comment:
    As a bariatric surgeon with many years of experience in providing high quality care to patients I feel that the CMS is correct in that centers of excellence is providing a barrier to access. I believe it is may have been a good idea in principle when initiated to make hospitals, insurers and surgeons aware of the need to have low complication rates and track outcomes such as long term weight loss and comborbidity resolution. I practiced at a hospital prior to centers of excellence, helped

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    Jantz, Kate Title: APRN
    Organization: Via Christi Weight Management
    Date: 07/18/2013
    Comment:
    I support the decision to withdrawl mandatory facility certification. Our smaller provisional program of 10 years has excellent outcomes. Despite these outcomes, ASMBS has continued to forever intimidate and dangle the "volume carrot". Sometimes I sense there is a personal agenda for larger programs with "whos who" surgeons behind this push. I think a quality improvement criteria are critical for safety. Perhaps modification of the current critera?
    Walrath, Nanette Title: Operations Manager
    Organization: ECU Weight Loss Surgery
    Date: 07/18/2013
    Comment:
    “I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.” We Support CMS Bariatric Surgery Facility Certification Because:
  • Patient Safety is Increased
  • Is Aligned with other Certification Programs
  • Medicare patients are Sicker
  • Access to Quality Care is Increased
  • Integrated Health is Supported
  • Federal Budget Impact is Neutral
  • Carpenter, Christine Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Caruana, Joseph Date: 07/18/2013
    Comment:
    I agree with CMS proposed change to allow bariatric surgery in programs other than those designated COE. If a bariatric surgeon has enough experience and appropriate outcomes, then the facility in which the bariatric procedures are performed does not need any special certification. However, I strongly endorse any bariatric program complying with the American College of Surgeons Quality Improvement Program for Bariatric Surgery.
    Tran, Kim Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I would like CMS Bariatric Facility Certification to continue.
    I support CMS Bariatric Surgery Facility Certification Because:
  • Patient Safety is Increased as Medicare patients have higher risk of morbidity and mortality than the general bariatric surgery population.
  • Access to Quality Care is Increased
  • Integrated Health is

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  • LaRaia, Kathleen Date: 07/18/2013
    Comment:
    Please support CMS Bariatric Surgery Facility Certification.
    Certified programs continually work for process improvements, standardization of care, positive outcomes and safety. Without certification the multidisciplinary team may diminish as programs look to curtail cost and reduce supportive infracture. The dietitian, RN, behavioral support are critical to improved outcomes. Since the CMS patients typically have additional co-morbidities then the general bariatric patient, all the

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    Cacucci, Brenda Title: MD FACS
    Organization: Meridian Surgical Group
    Date: 07/18/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    I Support CMS Bariatric Surgery Facility Certification Because:

  • Patient Safety is Increased
  • Is Aligned with other Certification Programs
  • Medicare patients are Sicker
  • Access to Quality Care is Increased
  • Integrated Health is Supported
  • Federal Budget Impact is

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  • Rohan, Christine Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. There are many positives and no negatives to continue this accreditation.
    Watkins, Brad Organization: University of Cincinnati Dept of Surgery
    Date: 07/18/2013
    Comment:
    I agree with dropping the requirement for Center of Excellence. Whereas the concept is good and we all agree with quality, the COE process has become too costly, inefficient, highly dysfunctional and puts politics ahead of patients. The ASMBS argument with SRC resulted in the COE process being non-existent for nearly two years which hurts patients and providers. The COE process ironically forces surgeons in many situations to provide inferior care to patients simply to check a COE box. We

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    Koop, Christine Date: 07/18/2013
    Comment:
    I disagree with the CMS decision to end
    Kelly, John Organization: UMassMemorial Medical Center
    Date: 07/18/2013
    Comment:

    Strongly feel that retracting credentialing efforts will severely impact quality and safety efforts established as a grassroots effort by Bariatric Surgeons nationwide.

    How can any medical or surgical group look be encouraged to improve the outcomes, create the data and transparency so desparately needed by our patients and our evolving health care system if our efforts will be so roundly defeated as seeming to "limit" access by the same federal govt who are demanding

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    Rohan, Christine Organization: Englewood Hospital and Medical Center
    Date: 07/18/2013
    Comment:
    There has been a steep decline in complications since the NCD 2006. There is no cost to anyone except the hospitals, private payors embrace and support accreditation as a standard of excellence. There is no reason to discontinue something that has so many positives and no negatives.
    Houck, Tina Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Villanueva MD, Ian Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Murray RN, BSN, CBN, Mary Title: Bariatric Surgery Program Coordinator
    Organization: Westchester Medical Center Valhalla, NY
    Date: 07/18/2013
    Comment:
    I strongly disagree with doing away with the ACS/ASMBS Bariatric Accreditation requirement. I have been working with Bariatric patients for 10 years(3 years as a nurse manager on the post op floor and 7 years as a Bariatric Program Coordinator) Our program has ranked in the top 5% of bariatric outcomes rated by Healthgrades since 2007 which is the year we started with accreditation. I am convinced that our outcomes are not only due to the expert surgical skills of our surgeons but also to

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    Nandipati, Kalyana Date: 07/18/2013
    Comment:
    I agree with the CMS policy regarding the certification. Most facilities are using it as a advertisement tool than outcome improvement tool. It need to be physician centered.
    Ewing, Douglas Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Thank you.
    Byer, Gregory Title: Bariatric Coordinator
    Organization: Windber Medical Center
    Date: 07/18/2013
    Comment:

    I feel very strongly that removing facility certification requirements could have a negative impact on care of the bariatric surgical patient.

    I believe that CMS Bariatric Facility Certification should continue based on current evidence that supports facility certification directly impacts patient safety, patient mortality rates, access to quality care, creates an integrated care approach, while remaining neutral in regards to budget impact.

    Severson, Paul Title: Co-Director
    Organization: Minnesota Institute for Minimally Invasive Surgery
    Date: 07/18/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. The improvements in the quality and safety of bariatric surgery at our facility and in other certified hospitals in our state has been dramatic, and we believe are directly attributed to the accountability requirements integral to the accreditation process. In addition, the quality processes put in place by certification has led to outcome measurement, teamwork, system-based

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    Popp, Rebecca Title: Bariatric Surgery Coordinator, RN
    Organization: Hays Medical Center, Hays KS
    Date: 07/18/2013
    Comment:
    I completely support CMS's proposal to stop requiring Center of Excellence certification for bariatric surgery coverage. As a small rural center who will never achieve COE status due to volume, I know personally that non-COE facilities can and do provide outstanding results with outcomes data comparable to (and sometimes better than)certified Centers of Excellence. A smaller program also allows us to focus intently on each individual patient, assuring quality care, customer satisfaction, and

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    Dominguez, Mark Title: Bariatric Surgeon and Managing Partner
    Organization: Northlake Surgical Association & Real Results Weight Loss Clinic
    Date: 07/18/2013
    Comment:
    I agree that there should be no 'Centers of Excellence". It is clearly evident that the pressure to continue with COEs is from those after their own self interest be it ownership in these facilities or are involved in their accreditation. I perform bariatric surgery at both a COE and a non-COE hospital and I actually feel my patients get as good or better care at my non-COE hospital. It is all about the surgeon and the trained ancillary staff. It has nothing to do with the facility or its

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    Davis, Melissa Organization: Scottsdale Healthcare Bariatric Center
    Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. This is a matter of patient safety. The only facilities taking care of Medicare Bariatric patients should be certified!
    Ceppa, Federico Title: Bariatric Surgeon
    Organization: The Reading Hospital Weight Management Center
    Date: 07/18/2013
    Comment:
    The center of excellence requirement has elevated the care that bariatrics patients have recieved. It has also allowed high volume centers to do higher risk patients with good results. The data suggest no difference; however, teasing out the data shows this is not nesseraly true. Access to care versus access to quality care are not the same thing. Having seen examples of non-center of excellence bariatric work in our emergancy room benefits no-one. By tracking data, outcomes, and

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    Moran MD FACS, Joseph Title: President, Advanced Laparoscopic Associates, PC
    Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Bovos, Christine Title: Bariatric Sugery Program Coordinator
    Date: 07/18/2013
    Comment:
    What the study CMS looked at regarding the effectiveness of COE's didn't take into consideration is the acuity of patients we are now seeing. Initially, there were a lot of medicare patients being done that were not terribly ill or their BMI's were in the 35 - 40 range. Now we are seeing people who are extremely ill, for whom this surgery is life saving, they are severely obese (many in the 60 - 90 range) and their comorbid conditions are much more severe. That isn't reflected in the data,

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    Holsworth, Cheryl Title: Senior Nursing Specialist Bariatric Surgery
    Organization: Sharp Healthcare
    Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Facilities with COE are better prepared to handle bariatric surgery emergencies. Furthermore, we do not capture the clinical outcomes of many non certified centers outcomes as they are not required to track the data. Please reconsider this decision. Thank you.
    Braja, Mary Title: BSCR
    Organization: Spartanburg Medical Center
    Date: 07/18/2013
    Comment:
    “I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.”
    Garren, MD, Michael Title: Professor of Surgery
    Organization: University of Wisconsin School of Medicine and Public Health
    Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Youn, Heekoung Date: 07/18/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue for the quality control of all bariatric procedures.
    Felts, MD, FACS, Frank Title: Medical Director, Bariatrics
    Organization: Mountainview Weight Loss Center
    Date: 07/17/2013
    Comment:
    I am the Medical Director and Primary surgeon at Mountainview Regional Medical Center, Las Cruces, NM. We started our Bariatric program September 2012. We are not yet COE. We will be ready to apply as soon as the new ASMBS standards are released. I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Thank you.
    parikh, manish Title: Director, Bariatric Surgery, Bellevue Hospital
    Organization: Bellevue Hospital Center/NYU School of Medicine
    Date: 07/17/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

    I believe that the facility certification has improved care. It has provided a blueprint for clinical success at our program. I do not believe it impacts access to care, as there is no shortage of accredited centers in our region (NYC). however the certification requirements have improved the process of

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    ahad, sajida Title: Assisstant Professor in Surgery
    Organization: SIU School of Medicine
    Date: 07/17/2013
    Comment:
    I agree with decision to lift COE requirements . However this may lead to untrained surgeons doing very complex surgeries in very small hospitals. I would recommend the surgeries to be performed in hospitals where there is a structural program to deal with all aspects of obesity and not just concentrate on numbers of surgeries performed.
    Volpe, Christine Date: 07/17/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Monday, Charles Title: chairman. Medical Quality Review Comm
    Organization: Huntsville Memorial Hospital
    Date: 07/17/2013
    Comment:

    Every 3-4 weeks I see a patient who needs a bariatric procedure. Life continues to carry a great burden for thes unfortunates who genetically cannot carry the extra 50 lbs without the inevitable hio and knee pain, decreased activity, more weight, diabetes and hypertention. Typically, in my practice, available work is physical more than mental. Next is disability and more weight. Bariatric surgery for these patients simply never gets done in the seemingly distant city of Houston where

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    Pryor, Aurora Organization: Stony Brook Medicine
    Date: 07/17/2013
    Comment:
    I support the decision of CMS to no longer require facility certification through the initial COE programs, however I think CMS needs to maintain facility requirements for bariatric surgery to be performed. Certification has improved the resources available to our patients at participating centers, including safety equipment for patients and providers. It has also forced providers to be aware of their outcomes, and consider expectations before operating. I think the new accreditation system

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    Trahan, Michael Date: 07/16/2013
    Comment:
    I applaud your efforts to review this policy. No special certification should be required for bariatric care of Medicare beneficiaries.
    Shukla, Urmil Date: 07/16/2013
    Comment:

    I strongly support CMS decision to do away with facility designation.

    We are a small hospital but we pride in doing great work, and will continue to do so.

    We have great results
    Patrick, Virginia Title: Bariatric coordinator
    Organization: SMMC
    Date: 07/16/2013
    Comment:
    I concur with the decision that CMS has decided
    Braslow, AnnaMarie Title: Clinical Bariatric Coordinator
    Organization: JT Mather Hospital
    Date: 07/16/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Having a certification demands processes are inplace and resources commited to the necessary pre/post and long term follow up to optimize patient safety and successful long term outcomes.
    anoosh, farhad Title: MD, FACS
    Organization: brookhaven hospital
    Date: 07/16/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    VanderPluym, Nancee Title: MS, RDN
    Date: 07/16/2013
    Comment:
    I believe the positive outcomes for bariatric surgery have improved since CMS required facility certification. A dual certification for surgeon/facility is essential to reduce morbidity/mortality for patients. If the number of required surgeries for a facility are being reduced to 50, I believe maintaining facility certification is essential to the welfare of the patients.
    Diwan, Tayyab Organization: UCMC
    Date: 07/16/2013
    Comment:
    I agree with CMS decision and am in support. I am fellowship trained bariatric surgeon and fully agree that a COE is not required and does not improve patient outcomes. Please refer to Dr. Justin Dimick's paper.
    Strano, Ginger Title: Bariatric Dietitian
    Organization: Center for Bariatrics, SOMC
    Date: 07/16/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    McCoy, RN, MSN, FNP-BC, Sandy Title: Bariatric Nurse Practitioner
    Organization: Baylor University Medical Center
    Date: 07/16/2013
    Comment:

    I am against not requiring Medicare/Medicaid patients to use a COE facility. I am a bariartic nurse practitioner at Baylor University in Dallas and we are COE. I have been at this facility for 3 years and although most of our patients are Medicare and have complex problems, we have not had one single death. This is compared to other facilities in Dallas that are not certified and have experienced deaths.

    We have a higher set of standards both preoperatively and

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    Armstrong, Kellie Title: Bariatric Surgery Program Coordinator
    Organization: The Center for Bariatric Surgery at The Miriam Hospital
    Date: 07/16/2013
    Comment:
    I truely believe that the Bariatric Facility Certification has been helpfull to promote the safety and continued growth of this type of surgery. I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. Thank you for taking the time to considering my comments on this subject.
    Thompson, Angela Title: Bariatric Practice Manager
    Organization: St. Elizabeth Healthcare Weight Management Center
    Date: 07/16/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Without accreditation, long-term data collection will be impaired and quality improvement efforts will be severely impeded. This Certification increases patient safety. Specific to the Medicare population, Nguyen in a 2010 Archives of Surgery article noted a 33% reduction in mortality in Medicare beneficiaries

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    Varela, Esteban Date: 07/16/2013
    Comment:
    I respectfully disagree with the CMS Bariatric Facility Certification proposed decision to remove Facility Certification. The literature and evidence is stronger toward the clinical and economic benefits of the current CMS Bariatric Facility Certification. Therefore, I strongly support its continuation.
    Shields, Jessica Date: 07/16/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Mulkey, Kim Title: Bariatric Program Coordinator
    Organization: Southern Surgical Hospital
    Date: 07/16/2013
    Comment:

    I disagree with the CMS proposed decision memo to remove Bariatric Facility Certification. Currently, all centers with the ASMBS/ACS Center of Excellence certification have gone through extensive approval processes which are set in place, most importantly, to improve overall patient safety. Medicare patients are a much more sick population than privately insured patients and typically have higher BMI's. It's imperative that a facility can accommodate morbidly obese patients from the time

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    Radecke, Jason Title: Surgical Attending
    Date: 07/16/2013
    Comment:

    My name is Dr. Jason Radecke and I am a fellowship trained Bariatric and Metabolic surgeon. I have practiced at both accredited and non-accredited facilities and have therefore experienced truly what it means to be non-accredited.

    I sincerely disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I am in strong favor of CMS Bariatric Facility Certification to continue.

    Thank you,
    Jason Radecke, MD
    Speakman, J Jared Organization: Utah Surgical Associates
    Date: 07/16/2013
    Comment:
    I am a surgeon who has been impacted by the decision to require patients to be sent to COE designated facilities. Prior to this decision over fifty percent of our bariatric patients were covered by Medicare and Medicaid. Since that decision we have had to send these patients hundreds of miles out of our community to centers where they have their operations. Families have to stay in hotels and if complications occur it is a significant hardship. Data shows that there are plenty of smaller

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    Cipriano, Joseph Title: D.O.
    Organization: Advanced Surgical Care
    Date: 07/16/2013
    Comment:

    Being a bariatric Surgeon in a rural site has many challenges to overcome and maintaining continuity of care as well as reasonable access to care is no exception. Many patients that are evaluated by our bariatric program are required to ultimately have their procedure at a COE due to current regulations. Patients are having to travel 5-6 hours to reach a facility that have COE certification. The relationship our office has with several COE facilities is excellent and we have always had

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    Eichhorn, Patricia Title: MIS and bariatric surgeon
    Organization: Greenville Health System/Bariatric Solutions
    Date: 07/16/2013
    Comment:
    I think a center of excellence should continue although it should be based on outcomes rather than total number of cases. Getting rid of COE will lead to any general surgeon doing bands and sleeves without proper follow up. This would result in transferring patients to established programs for complication management like leaks and slips.
    Carrasca, Rachael Date: 07/16/2013
    Comment:
    “I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.”
    Glover, Carla Title: Bariatric Program Coordinator, RN, BSN, CBN
    Organization: Weight Loss Services - Spartanburg Medical Center
    Date: 07/16/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

    I Support CMS Bariatric Surgery Facility Certification Because:
    • Patient Safety is Increased
    • Is Aligned with other Certification Programs
    • Medicare patients are Sicker
    • Access to Quality Care is Increased
    • Integrated Health is Supported
    • Federal Budget

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    Ferraro, Dorothy Title: Clincal Director of Bariatric Service, DNP
    Organization: Stamford Hospital
    Date: 07/16/2013
    Comment:
    I am in disagreement with the proposed decision to remove Facility Certification for Bariatric Services, and firmly believe CMS Bariatric Facility Certification should continue. Since the implementation of the original 2006 National Coverage Determnation for Bariatric Surgery, I have witnessed improvements in patient safety in the bariatric patient population. I have been instrumental in the development of three hospital programs, and believe having to meet well-defined standards has

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    Slavik, Jolene Date: 07/16/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    McPhee, Joseph Date: 07/16/2013
    Comment:
    I disagree with the CMS change in policy in removing required facility certification for bariatric surgery.
    Becker, Elaine Title: Bariatric Clinical Resource Nurse (RN)
    Organization: Midwest Bariatric Solutions
    Date: 07/16/2013
    Comment:
    “I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.”
    SCOTT, JULIE Title: MANAGER
    Organization: MIDWEST BARIATRIC SOLUTIONS
    Date: 07/16/2013
    Comment:
    BARIATRIC SURGERY IS AN EFFECTIVE TOOL FOR PATIENTS SUFFERING MANY CO-MORBID CONDITIONS. HAVING SURGERY PERFORMED AT A CENTER WHERE THEY ARE REGULATED ON THE QUALITY OF THE CARE AND STANDARDS OF CARE NECESSARY SPECIFICLY TO THE BARIATRIC PATIENT IS EXTREMELY IMPORTANT FOR THE SAFETY OF THE PATIENTS COVERED BY CMS. IF YOU REQUIRED A TRANSPLANT WOULD YOU GO TO A CENTER THAT ONLY DOES THEM ONCE IN A WHILE OR TO A CENTER WHO DOES HUNDREDS OF THEM A YEAR AND HAS THE EXPERTISE TO CARE FOR YOU AND

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    DeLuca, Roseann Title: Bariatric Coordinator
    Organization: Good Samaritan Hospital Medical Center
    Date: 07/16/2013
    Comment:
    I disagree with the CMS decision and feel that all Bariatric Surgery Centers should be held to standards and guidelines and their needs to be a governing body to ensure these guidelines are met and standard of care is provided for all of these patients.
    Strain, Gladys Title: Direcctor of Research for Metabolic and Bariatric
    Organization: Weill Corneedll School of Medicine
    Date: 07/16/2013
    Comment:
    The certification requirement assures patients they are obtaining healthcare in a safe appropriate center with a staff that is qualified. This procedure should not be disbanded.
    Grondin, Thomas Title: Product Line Administrator
    Organization: Memorial Hospital of Tampa
    Date: 07/16/2013
    Comment:

    " In the proposed decision to remove certification requirements for Bariatric Surgery for the Treatment of Morbid Obesity (CAG-00250R3) is a proposal in the third paragraph of the Decision Summary that states:

    "Lastly, we propose to change the title to better reflect the scope of the NCD and to make it clear in the manual that under the existing policy the local Medicare Administrative Contractors have the authority to make coverage decisions for any bariatric procedures not

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    Dixon, Ingrid Title: Director of Perioperative Services
    Organization: Huntsville Memorial Hospital
    Date: 07/16/2013
    Comment:
    I fully support the decision to decrease the requirements for bariatric facility certification. The new requirement will enhance and encourage the development of smaller organization's ability to preform these much needed procedures while still striving to provide the identified population excellent, safe, quality health care.
    Bush, Kathryn Title: Registered Dietitian
    Organization: Aspirus Wausau Hospital Bariatrics
    Date: 07/16/2013
    Comment:
    Maintenance of a Facility Certification Requirement (COE) is paramount to ensure the safety and quality of bariatric surgery. I fear that inadequately trained and equipped facilities will begin offering bariatric services merely on the basis of profit, which will jeopardize patient safety. A successful outcome in the treatment of obesity demands a highly trained surgeons, properly equipped hospitals, and a team of specialists such as physical therapists, registered dietitians and

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    huerta, Gustavo Date: 07/16/2013
    Comment:
    I am a Bariatric surgeon, that has seen a restriction for my patients ability to have appropiate care in our institution because of the Certification, our quality of care and outcomes are as good as the centers of exellence, and our patients have to travel to obtain the same care, that can be provided here, in our comprehensive bariatric program . I welcome the CMS change of policy, as I have not seen a benefit for our patients, comunity and hospital imposed by the certification.
    Haase, Diana Title: Bariatric Surgery Program Leader
    Organization: Borgess Medical Center
    Date: 07/16/2013
    Comment:

    I support CMS Bariatric Surgery Facility Certification!

    Since the CMS NCD supporting accreditation, lives have been saved, complications have been prevented, readmissions have been averted, cost has been lowered and access has been broadened. Without accreditation, long-term data collection will be impaired and quality improvement efforts will be severely impeded. CMS Facility Certification has worked since 2006. Let’s continue our progress.

    I support CMS Bariatric Surgery

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    Ahmed, Leaque Title: Medical Director of Bariatric surgery
    Organization: Harlem Hospital Center
    Date: 07/16/2013
    Comment:
    I believe facilty certification is important for patient safety. I disargree with the CNS decision to remove the facility certification requirement. I would like the facility certification to continue.
    Lim, Robert Title: Chief of Metabolic and Advanced Laparoscopic Surge
    Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. This decision is not based on patient safety and goes against the historical aim of CMS which is to improve the quality of patient care.
    VERSCHELL, MARK Title: Director, LEAN Healthy Lifestyles Program
    Organization: Tripler Army Medical Center, Hawaii
    Date: 07/15/2013
    Comment:
    I am in support of continuing facility certification. I am a clinical psychologist and provider of bariatric surgery healthcare in a military medical treatment program. My professional responsibilities in bariatric healthcare are to prepare patients for surgery and to facilitate appropriate health behaviors following surgery. Although my services are identified as exceedingly important by my program's treatment team and colleagues in bariatric healthcare, they are rarely duplicated in the

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    Selzer, Don Title: Associate Director, Division of General Surgery
    Organization: Indiana University School of Medicine
    Date: 07/15/2013
    Comment:

    The arguments that favor the repeal are likely most fervently presented in the article published in JAMA in February of this year. Unfortuntely, this article fails to account for one of the most important variables that impacts outcomes: BMI. If one looks at the data, there is an increase in all known characteristics associated with an increase risk of complication. There are more males. There are more patients with hypertension. The average age rose to 55 years of age. Finally, the

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    Paine, Stacy Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Salimath, Jayaraj Title: Minimally Invasive general and Bariatric Surgeon
    Organization: Mid Illini Surgical Associates/ Methodist Medical Center of Ill
    Date: 07/15/2013
    Comment:
    I strongly agree with CMS decision. COE has become exclusive club. Many competitive groups in small town have been using exclusive agreements between hospitals and group to keep their competitive well qualified, and young fellowship trained bariatric surgeons out of their centers in the name of COE. My outcomes have been better than national average at COE, and I have lot of medicare patients come to me because of quality and safe care. Unfortunately, due to local competition, I have not been

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    Ward, David Date: 07/15/2013
    Comment:
    I agree with your change in policy to eliminate centers of excellence for bariatric surgery. The creation of centers of excellence for bariatric was arbitrary. The quality of any hospital depends on the surgeons and nursing staff which is not examined during this process. I belong to a center of excellence hospital and the key to excellent patient care is examining patient outcomes and making the necessary corrections. I agree with eliminating centers of excellence.
    Thank

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    Christophersen, Matt Date: 07/15/2013
    Comment:
    I disagree with the decision to possibly discontinue the Bariatric Facility Certification requirement to provide bariatric surgical care to medicare beneficiaries
    Padilla, M.D., F.A.C.S., Joe Title: Surgeon
    Organization: Summit Medical Center
    Date: 07/15/2013
    Comment:
    As the evidence indicates this change is well overdue. I have patients who have to travel hours to get their surgery done just because they have Medicare or Medicaid, whereas other patients with private insurance are getting it done in their hometown with excellent results. I get requests and complaints from patients that have to travel every week.
    Wolfe, Bruce Title: Professor of Surgery
    Organization: Oregon Health and Science University
    Date: 07/15/2013
    Comment:

    Dear CMS,

    I am writing to support the CMS policy requiring accreditation of bariatric surgical centers. The evidence supporting a requirement for bariatric surgical center certification has been delineated in detail by Drs. Ponce, Nguyen, Morton and Blackstone of the American Society for Metabolic and Bariatric Surgery. This response has been prepared with input from many critical reviewers and is well-supported by the cited literature. The present combined effort of the

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    gandhi, alok Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Treen, David Title: President and CEO
    Date: 07/15/2013
    Comment:

    I wholeheartedly support the CMS LIFTING OF COE CERTIFICATION.

    All of the examples of benefits of COE are the result of surgeons hard work, NOT the COE process, or certification.

    COE designation has not benefited my practice at all, and has actually caused me to have to spend more money to be eligible for continued certification. The COE process is nothing more than a scheme to keep the leadership in power over the membership. It's like a serfdom; the masses (surgeons)

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    Parker, Amanda Title: M.D.
    Organization: Virginia Hospital Center
    Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Hetzel, Teri Date: 07/15/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

    I Support CMS Bariatric Surgery Facility Certification for the following reasons:

    • Patient safety is increased
    • Is aligned with other Certification Programs
    • Medicare patients are sicker
    • Access to quality care is increased
    • Integrated health is

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    Kurian, Marina Date: 07/15/2013
    Comment:
    I believe in certification of centers for bariatric surgery. I think our outcomes have improved because of ensuring clinical pathways, designated bariatric care areas and equipment and engaging the administration in a meaningful way. The federal budget is not affected with this certification process. The hospital process ensures integration and buy in of all parties. Patient safety has been improved with the center of excellence certification.
    Muscari, Donna Title: RN Bariatric Nurse
    Organization: Health-First
    Date: 07/15/2013
    Comment:
    As a bariatric nurse and at a facility who just completed there first COE I cannot tell you how setting up the program for the certificiation is grueling. However the points that it brings out is setting up standards for all bariatric patients that we can all go by which increase patient saftey and improved outcomes for all bariatric patients. Often medicare patients are higher risk patients and having pathways and standard plan of care often avoids complications post-op. Data in MSQIP will

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    Robarts, Kelsey Date: 07/15/2013
    Comment:
    I fully support CMS decision to abandon COE policies.
    Ihde, Glenn Date: 07/15/2013
    Comment:
    The issue of obesity in America is one that has undergone extensive scrutiny. In efforts to decrease the rates of morbidity and mortality, the Center of Excellence concept was developed, but studies have shown that there is little if any difference in outcomes in designated versus non-designated centers. What has occurred, is the stagnation of the provision of care. Countless Americans are suffering without access to care because the designation limits facilities that can provide care.

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    Robarts, Susan Date: 07/15/2013
    Comment:
    I fully support CMS' decision to abandon COE requirements for bariatric surgery. COE has limited access to care without showing benefit for patients.
    Robarts, Tim Title: MD
    Organization: Huntington Internal Medicine Group
    Date: 07/15/2013
    Comment:
    I fully agree with the CMS decision to abandon COE requirements. There is no benefit with respect to outcomes and it has severely limited access to care in my community.
    nepomnayshy, dmitry Title: surgeon
    Organization: lahey clinic
    Date: 07/15/2013
    Comment:
    i think it would be a mistake to remove the facility certification requirement when performing bariatric surgery. There are multiple examples in the literature how other requirements - along with other quality initiatives like JHACO and MAGNET status for nursing and NCI accredited CANCER CENTERS show is that when specific requirements are instituted and audited, results improve and complications and mortality decrease. Removing this requirement for bariatric surgery would be a major step

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    Singh, Manish Date: 07/15/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

    We Support CMS Bariatric Surgery Facility Certification Because:

    1)Patient Safety is Increased
    2)Is Aligned with other Certification Programs
    3)Medicare patients are Sicker
    4)Access to Quality Care is Increased
    5)Integrated Health is Supported
    6)Federal Budget Impact is Neutral
    Patterson, Mistey Organization: My Bariatric Solutions
    Date: 07/15/2013
    Comment:

    We Support CMS Bariatric Surgery Facility Certification Because:

    Patient Safety is Increased
    Is Aligned with other Certification Programs
    Medicare patients are Sicker
    Access to Quality Care is Increased
    Integrated Health is Supported
    Federal Budget Impact is Neutral
    Antanavicius, Gintas Title: MD, FASMBS
    Organization: Abington Helath
    Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Wilson, Nanette Title: Patient Representative
    Organization: Obesity Prevention and Policy Management
    Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. The COE accreditation was established to ensure patient safety and I believe removing it from the requirements of surgical weight loss procedures will cause harm to patients.
    Kenney, Robert Title: Bariatric Surgeon
    Organization: Western Missouri Medical Center
    Date: 07/15/2013
    Comment:

    To whom it may concern,

    I am a fellowship trained bariatric surgeon who serves in a rural community in western Missouri. Our center performs around 50 bariatric cases a year with excellent results. The nearest center of excellence is one hour away. Many Medicare patients are not able to drive an hour away for this life saving service. The literature is fairly clear that the COE programs do not improve outcomes. I STRONGLY AGREE WITH THE PROPOSAL TO ELIMINATE THE REQUIREMENT

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    Bessler, Marc Date: 07/15/2013
    Comment:
    I strongly disagree with the proposal to eliminate the requirement for facility certification. The evidence while not overwhelming falls on the side of favoring improved outcomes for COE's. Certainly the higher risk, Medicare, patients would be served better in experienced centers. There is no evidence I a aware of that suggests access to care has been limited by the Center Certification requirement. Certainly the requirement has brought hospitals to the table in providing necessary resources

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    Peltz, Melanie Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Taylor, Jamokay Title: Medical Director
    Organization: Warrenton Weight Loss Institute
    Date: 07/15/2013
    Comment:
    I disagree with the decision to abandon the CMS center certification requirement for bariatric surgery. There is data that clearly shows a cost benefit and a safety benefit in certified centers, and I feel it would be a detriment to our patients should this certification requirement be discontinued.
    Bauer, Christine Date: 07/15/2013
    Comment:
    I DO NOT agree with CMS proposed NCD to eliminate the requirement that facilities performing bariatric procedures be certified as centers of excellence.
    Sloan, Dale Sloan MD Date: 07/15/2013
    Comment:

    I Support CMS Bariatric Surgery Facility Certification Because:

    Patient Safety is Increased
    Is Aligned with other Certification Programs
    Medicare patients are Sicker
    Access to Quality Care is Increased
    Integrated Health is Supported
    Federal Budget Impact is Neutral

    Please reverse the decision to eliminate the Certified Program requirement.

    Dale Sloan MD
    Talbot, Andrea Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.”
    Schmeeckle, Jill Organization: Alegent Creighotn Health
    Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Paull-Forney, Bobbie Title: Clinical Outcomes Specialist / RN
    Organization: Via Christi Hosptals
    Date: 07/15/2013
    Comment:
    I agree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. We have an excellent outcomes based program that continues to fail to meet the volume requirements. Therefore, hundreds of patients that could have been served here locally have been required to travel three or more hours to the nearest accredited center.
    Malaskovitz, Joyce Title: Director Health and Wellness Services
    Organization: Desert Springs Hospital
    Date: 07/15/2013
    Comment:
    “I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.”
    Carmine, Brian Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue
    Oldham, John Date: 07/15/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue to ensure quality care is given to all patients consistently. Designation proves that the facility and surgeon are committed to providing exceptional and safe pre-operative, operative and post-operative care. Our Program and I are committed to providing the education needed at all levels to staff who care for this high

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    McNamara, Donna Title: CRNP
    Organization: Abington Health-Institute for Metabolic and Bariatric Surgery
    Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Chapmon, Katie Date: 07/15/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

    I feel that by having a certification system, it allows for increased patient safety. Without any reference, you will see that over time, quality of care will be reduced.

    Medicare patients are usually sicker, which requires a surgeon, facility and team with experience to better and positive

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    Suarez, Stacy Title: MA Medical Weight Loss Coordinator
    Organization: North Ottawa Community Health Systems Bariatric Clinic
    Date: 07/15/2013
    Comment:
    I believe that there is no real evidence showing that the outcomes are any different from a COE facility verses an non COE. I am looking forward to seeing this not being a requirement any longer so we can properly accomodate our MCR patients.
    Scott, John Title: Surgeon
    Organization: Greenville Health System
    Date: 07/15/2013
    Comment:
    I think the CMS proposal to end COE designation is a terrible idea for Medicare patients. COE protects patient safety, increases quality based research efforts, increases public awareness of specialized centers, and treats the sicker Medicare population with the premium care. The move to abolish COE status will take us back to the 70's and 80's when patient outcomes were poorer and safety and qaulity were words that only applied to the airline industry. This is a shocking decision that will

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    Mortonson, Mark Title: Bariatric Program Director
    Organization: Southern Oregon Bariatric Center @ Oregon Surgical Specialists
    Date: 07/15/2013
    Comment:
    “I agree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I do not want, nor see the overall value to patient care of CMS Bariatric Facility Certification continuing.”
    Grams, Jayleen Date: 07/15/2013
    Comment:
    I disagree with the decision memo to entirely remove Facility Certification. I think certification has improved hospital safety and facilities as well as the development of a programmatic multidisciplinary approach to treat bariatric patients. However, I think the criteria need to change from VOLUME to OUTCOMES.
    Spykes, Rhonda Title: Bariatric Clinical Coordinator
    Organization: Odessa Regional Medical Center
    Date: 07/15/2013
    Comment:
    I agree with CMS statements regarding bariatric surgery. The COE designation is profitable financially for the ASMBS. Centers without the designation are capable of providing quality care to bariatric patients.
    Gentles, Charmaine Date: 07/15/2013
    Comment:
    I'm in favor for Facility Certification requirement as this supports a safer environnment for the patients.
    Noonan, Kristin Date: 07/15/2013
    Comment:

    I Support CMS Bariatric Surgery Facility Certification Because:

    • Patient Safety is Increased
    • Is Aligned with other Certification Programs
    • Medicare patients are Sicker
    • Access to Quality Care is Increased
    • Integrated Health is Supported
    • Federal Budget Impact is Neutral
    Schledorn, Elizabeth Organization: Winthrop University Hospital (Mineola, NY)
    Date: 07/15/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

    I Support CMS Bariatric Surgery Facility Certification Because:
    • Patient Safety is Increased
    • Is Aligned with other Certification Programs
    • Medicare patients are Sicker
    • Access to Quality Care is Increased
    • Integrated Health is Supported
    • Federal Budget

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    Vaughan, Jefferson Title: Medical Director
    Organization: Institute for Metabolic and Bariatric Surgery
    Date: 07/15/2013
    Comment:
    “I AGREE with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I DO NOT want CMS Bariatric Facility Certification to continue.”
    Fortier MD, FACS, George Title: Director Bariatric Surgery
    Organization: Stevens Community Medical Center and CentraCare Long Prairie
    Date: 07/15/2013
    Comment:
    As a regular member of the ASMBS I believe the COE program should be abandoned. I have complained in the past that it does not result in improved outcomes. The COE requirement restricts access to care for many rural residents and adds considerable cost. The certification is expensive and adds nothing to the care of patients. Get rid of the COE requirement!!
    Price, Bobbie Lou Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Williams, Eileen Title: Weight Loss & Wellness Center Coordinator
    Organization: Johnson Memorial Hospital
    Date: 07/15/2013
    Comment:
    I agree with the decision to disband the Centers of Excellence requirement for bariatric surgery. I am the Coordinator for bariatric surgery program in a small community hospital with wonderful outcomes and superb surgreon who has done over 700 cases to date. We are unable to provide services to many people due to this regulation. I agree with the continuation to keep outcomes data and work toward the best outcomes but not with COE requirment! I feel the ability of a person to choose the

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    wetherill, tim Title: MD, Medical Director Christus St Vincent Bariatric
    Date: 07/15/2013
    Comment:
    I applaud CMS and the physicians behind the decision to recognize the fact that COE has never provided improved outcomes for patients. I do believe that bariatric surgery does need some guidelines. The surgery itself is not what should be regulated however the system/programs should receive scrutiny. There are far too many "programs" which offer patients no follow up or longterm guidance. thanks you
    Kim, Benjamin Organization: Kaiser PermanenteWest Los Angeles Medical Center
    Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I believe CMS Bariatric Facility Certification is invaluable and want it to continue.
    koehler, kathryn Title: Chief Nurse Executive
    Organization: Immanuel Medical Center
    Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue in order to adequately keep tpateitns safe. Bariatric surgery is still a high risk procedure on VERY high risk individuals due to complications and co-morbid conditions associated with morbid obesisty. Certification requires rigid standards for saefty. Meeting som eof these standards can be costly and if the certification

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    Rogers, Ann Title: Director, Penn State Surgical Weight Loss Program
    Organization: Penn State Hershey Medical Center
    Date: 07/15/2013
    Comment:
    I strongly urge CMS to continue to support and require Center of Excellence status for certified bariatric surgery facilities.
    richardson, william Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Barnett Sparks, Karen Title: Bariatric Coordinator-BSN, Certified Bariatric RN
    Organization: Baptist Health Louisville
    Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue to ensure quality care is given to all patients consistently. Designation proves that the facility and surgeon is committed to providing exceptional and safe pre-operative, operative and post-operative care. Our Program and Surgeon are committed to providing the education needed at all levels to staff who care for this high

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    Kunkel, Carol Title: Bariatric Program Coordinator
    Organization: WSP General and Bariatric Surgery
    Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Leis, Jennifer Title: Practice Manager
    Organization: Kettering Physicians Network
    Date: 07/15/2013
    Comment:
    As a practice manager in bariatrics since 2003, I feel that the requirement for facility certification is a benefit in maintaining the necessary criteria for patient care and outcomes.
    Ku, James Title: Medical Director, Bariatric Surgery
    Organization: Lancaster General Health
    Date: 07/15/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.

    Quality in Bariatric Surgical care has made great strides during the era of Facility Certification. Removing this certification requirement would undo much of the progress we have made as a bariatric community.
    Galvani, Carlos Title: MD Director Minimally Invasive/Bariatric Surgery
    Organization: University of Arizona Health Network
    Date: 07/15/2013
    Comment:

    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. The reasons I support the facility certification are;

    • Patient Safety is Increased
    • Is Aligned with other Certification Programs
    • Medicare patients are Sicker
    • Access to Quality Care is Increased
    • Integrated Health is Supported
    • Federal Budget Impact is

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    Proulx, Debra Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. It is important for CMS Bariatric Facility Certification to continue. It provides for a standard of care that our patients deserve.
    Cross, Amanda Title: Program Director
    Organization: Wise Regional Health System
    Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I am in support of tracking quality and patient safety standards. Removing the COE requirement would remove both quality and safety.
    KEshishian, MD, Ara Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue
    Varghese, Mathew Title: Patient Coordinator
    Organization: http://bariatricbridge.com/
    Date: 07/15/2013
    Comment:

    Bariatric Bridge disagrees with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue. We are heavily involved in patient support, patient access to healthcare and good outcomes with bariatrics. CMS decision is a step back in fighting obesity. The nation as a whole is suffering and the Facility Certification program was the right step in moving forward. Four main private payors have

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    Lum, Nancy Title: President/Owner
    Organization: The GI and Bariatric Nutrition Center LLC
    Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue as it is protecting patients from the poor care that the "surgery factories" provided prior to ASMBS.
    Clark, Keri Title: Program Coordinator
    Organization: The Medical Center Surgical Weight Loss Program
    Date: 07/15/2013
    Comment:
    Thank you for the proposed change in COE. It will be a great relief to our patient's that they do not have to go out of town because we, as a new, small program, haven't obtained COE status. We take excellent care of all of our patient's and see the benefit of continuing the database registry. As we grow, we would like to obtain COE but as a benefit, not as a requirement.
    Vala, Barbara Title: Bariatric Coordinator
    Organization: Norwalk Hospital
    Date: 07/15/2013
    Comment:
    I Support CMS Bariatric Surgery Facility Certification Because:
    • Patient Safety is Increased
    • Is Aligned with other Certification Programs
    • Medicare patients are Sicker
    • Access to Quality Care is Increased
    • Integrated Health is Supported
    • Federal Budget Impact is Neutral
    Mitchell, Julienne Title: Bariatric Coordinator
    Organization: Community Memorial Health System
    Date: 07/15/2013
    Comment:
    We support accreditation for Bariatric Surgery. Accreditation has brought about standards that has made bariatric surgery safer for the patient. It is supported by clinicians across the hospital and focuses needed light on the special needs of the patient population. Medicare patients are often sicker than other patient populations. This alone makes it important to ensure that all of the safe guards are in place.
    Kini, Subhash Title: Asst. Prof.
    Organization: Mount Sinai Medical Center
    Date: 07/15/2013
    Comment:
    I think that we should continue the centers of Excellenece to continue the high level of care and good outcome sthat have resulted from this initiative. Stopping this can easily lead to lowering of standards in some institutions and thus resulting in overall worse outomes.
    Broussard, Toby Date: 07/15/2013
    Comment:
    I am a member of ASMBS and I do not support their view. I believe that COE is a good thing but if we are truly interested in outcomes for weight loss surgery, the data does not support COE as a determining factor in quality outcome following surgery. I fully support the proposed changes.
    Sempf, Teri Title: Bariatric Surgery Center Manger
    Organization: Park Nicollet Clinic
    Date: 07/15/2013
    Comment:
    I believe it is important to certify baratric facilities. I do not support the recommendation to discontinue certification of facilities.
    Fedorak, Ihor Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Loveless, Jessica Title: Bariatric Program Line Manager
    Organization: Baptist Health Medical Center
    Date: 07/15/2013
    Comment:
    Please reconsider the proposal to suspend the requirement for Facility Certification Requirement for Bariatric Surgery. As a healthcare professional dealing with this patient population, I can say this could result in many lost tax payer dollars by treating patients whom recieve bad surgery from inexperienced providers. Bariatrics have a whole set of complications and long process that are necessary to provide safe care. It takes a whole team dedicated to Bariatrics to plan and provide

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    Wolff, Andrea Title: Bariatric Surgery Program Coordinator
    Organization: ThedaCare
    Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Blythe, Lorie Title: CNS, Metabolic & Bariatric Coordinator
    Organization: IU Health Bariatric & Medical Weight Loss
    Date: 07/15/2013
    Comment:
    I disagree with the CMS Bariatric Facility Certification proposed decision memo to remove Facility Certification. I want CMS Bariatric Facility Certification to continue.
    Jamal, Mohammad Title: Director of Weight Loss Surgery Program
    Organization: HCA Hospital
    Date: 07/15/2013
    Comment:

    I think the CMS decision to abandon facility certification requirements is valid and I fully support it.

    This step will allow lower volume hospitals with clinically proven and safe Bariatric Surgery Programs to thrive and allow them to perform more cases and so extend better coverage to patients in their area.
    Fregia Rucks, Kristi Organization: Aspirus
    Date: 07/15/2013
    Comment:
    I disagree with CMS opinion on bariatric surgery COE. The reason bariatric surgery is safer now is BECAUSE of COE's. COE is the whole reason that starndards in bariatrics have changed. Only competent surgeons and competent programs are doing the surgeries now. Please keep the COE standard as a qualifier to continue the efforts in making bariatric surgery safe and effective treatment for obesity.
    Sugerman, Harvey Title: Emeritus Professor of Surgery
    Organization: Virginia Commonwealth University
    Date: 07/13/2013
    Comment:

    Jyme H. Shafer, MD, MPH
    Director, Division of Medical and Surgical Services
    CMS/OCSQ/Coverage and Analysis Group
    7500 Security Blvd, Mailstop C1-09-06
    Baltimore, MD 21244

    re: Bariatric NCD

    I have learned to my great disappointment that CMS is considering dropping the requirement for accredited centers for the bariatric NCD. In my opinion, this is a huge mistake. Furthermore, I have concerns regarding how this change was requested.

  • Did

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  • Schaffer RN BSN CBN, Lisa Title: Bariatric Coordinator
    Organization: Boone Hospital Center
    Date: 07/10/2013
    Comment:
    I am in full support of this decision by CMS. Our facility is in a more rural area and has always just been out of reach of the volume requirements for COE designation. We deliver very high quality care with extremely low complication rates to our bariatric patients. Our Medicare patients will now also have improved access and the benefit of receiving high quality bariatric surgery care as well.
    Ponce, Jaime Title: Bariatric Surgery Medical Director
    Organization: Hamilton Medical Center
    Date: 07/10/2013
    Comment:

    I am a bariatric surgeon and work in two facilities and both are accredited Bariatric Surgery COE centers. Have been practicing for more than 14 years and have seen the trends of issues. Before the concept of “Bariatric Surgery Center of Excellence (BSCOE)” we did had on one side an exponential growth of bariatric procedures after 1999-2000 (Davis MM, Slish K, Chao C, Cabana MD. National trends in bariatric surgery, 1996-2002. Arch Surg. 2006 Jan;141(1):71-4) and along with that came the

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    Nguyen, Ninh Title: Chief, Division of GI Surgery
    Organization: University of California Irvine Medical Center
    Date: 07/09/2013
    Comment:

    As a bariatric surgeon and an author on one of the few publications examining the role of accreditation in bariatric surgery, I disagree with the proposed decision to remove the requirement for facility certification. Our study examining the outcome of accredited compared to non-accredited centers showed more than a 3-fold lower mortality within accredited centers. Understanding the limitations that the analysis was performed within academic centers, it is important to acknowledge that our

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    Garver, James Title: Private Citizen
    Date: 07/09/2013
    Comment:

    Having been intimately involved as part of the physician/industry group who originally advocated for the creation of the NCD in 2005/2006 I am adamantly opposed to the language in the decision memo to no longer require certification of bariatric surgery facilities. While both employed with a company that offered a product used in the treatment of the morbidly obese, [PHI Redacted] I had the luxury of knowing who the best surgeons were and which facilities to go to. The

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    Bissell, Charles Date: 07/06/2013
    Comment:
    I am in favor of REMOVING the requirement for bariatric procedures being performed at designated Centers of Excellence. This requirement has limited access to needed treatment for large numbers of people particularly in rural settings. Bariatric patients benefit from ongoing support from bariatric programs. Distance to a COE is an impediment to good care. The surgery itself is one aspect of a patient's care. It has been demonstrated that procedures can be safely be done outside of a COE.
    Melton, Howard Title: General Surgeon, Hospital Authority Member
    Organization: Colquitt Regional Medical Center
    Date: 07/05/2013
    Comment:
    I have been doing bariatric surgery in a community hospital in south GA for 5 years and applaude the decision to drop the COE requirement for medicare patients. The restrictive nature of the current policy seriously limits the availablility of the procedure for a large group of patients that would benefit greatly from it. This will make it MUCH easier for those patients to get help with a life-threatening and life-shortening illness.
    McKee, Carolyn Title: RN, Bariatric Coordinator
    Organization: Clark Memorial Hospital
    Date: 07/03/2013
    Comment:
    I think this is a wise decision. We are a small hospital (188 beds) and we will not have the volume that is required to become a COE. It is not about numbers it is about care. We (RN's) take excellant care of our patients see them weekly (no charge) for evaluation and help with lifestyle changes.We work closely with our surgeons.This is a team effort. We are so thankful you finally saw that its not about numbers it is patient care and followup.There is no COE in Southern In, this will be very

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    Morse, D.O., Andrew Date: 07/01/2013
    Comment:
    I fully agree with the decision of CMS regarding doing away with the COE requirement. It is about time that EXCELLENT Bariatric Centers in Rural areas are able to provide the care their patients need without the COE designation. We have dozens of Medicare patients who are unable to get the weight loss surgery they want and need because they are afraid to drive 4 hours over often dangerous mountain passes to get to a COE.
    Perez, Carrie Date: 07/01/2013
    Comment:
    I am very pleased to hear the proposed decision to no longer continue the COE requirement for medicare beneficiaries but at the same time a little concerned about the future for standards in bariatric medicine. We are located in rural area with the closest COE facility 3 hours south and 3 hours west of us. We currently refer our patients having medicare 5 hours south due to ease of the referral process. We have built our program by observing other programs that currently have COE and by also

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    Showell, RN, Greg Title: Bariatric Program Coordinator
    Organization: Good Samaritan Regional Medical Center
    Date: 07/01/2013
    Comment:
    The removal of this artificial barrier to care will be a huge boon to patients living outside of major metropolitan areas. I applaud CMS for making this decision and understanding that volume alone does not accurately reflect the effectiveness of a bariatric program.
    Stracke, Michelle Date: 07/01/2013
    Comment:
    I am in full agreement and support of the proposed Decision by CMS. I have worked in a quality bariatric hospital program, focusing on both short & long term patient outcomes for 6 years, at a non COE facility. We have had to turn countless CMS patients away for bariatric surgery with our program due to the COE requirement, of which our program didn't meet the volume requirment to support. If CMS is going to change it's current policy based on such findings put forth from the Michigan

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    Muhlestein, David Date: 07/01/2013
    Comment:

    As part of a recent project I studied bariatric surgery and how Medicare's 2006 NCD affected the rate of bariatric surgeries among the non-Medicare population to quantify the spillover effect of a Medicare reimbursement or coverage policy. My research, using HCUP NIS data, found that there was considerable spillover onto the non-Medicare population, so any improvements in Medicare beneficiaries' outcomes could also be seen among non-Medicare patients.

    I did not compare quality

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    Barnett, Michele Title: RN, BSN, CBN-Bariatric Program Manager
    Organization: Mease Dunedin Hospital-BayCare Health System
    Date: 07/01/2013
    Comment:

    Dear Sirs:

    I agree with this decision 100%. Patients have the ability to choose to have surgery with an institution in which they trust to deliver the best care for them. While I am a member of the ASMBS, and I believe that patients deserve the best quality care, the credentialling has been out of reach for my program due to the volume requirment. I have had to turn away Medicare patients who have used our facility (BayCare Health System) and trust us with their care for every

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    Giammona, MD, MPH, Mary D. Title: Chief, Managed Care Services
    Organization: LA County Dept of Health Services
    Date: 06/28/2013
    Comment:
    I support CMS' proposed NDC revision to remove the facility certification requirement for bariatric surgery for the treatment of morbid obesity. Beyond posing an access barrier for rural communities, the Medicare facility certification has also been a barrier for urban areas serving low-income Medicaid populations. This is particularly so in states such as California, where the Medicaid guidelines for authorization of bariatric surgery required the surgery to be done at a Medicare-approved

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    Winfree, Gina Title: Bariatric Program Coordinator
    Organization: Baylor All Saints Medical Center
    Date: 06/28/2013
    Comment:
    I BELIEVE THIS IS THE CORRECT RULING. THE COE DESIGNATION HAS BECOME A LARGE GENERATOR OF INCOME FOR THE ACCREDITING AGENCIES, WHERE ALL THE BARIATRIC PROGRAMS I HAVE WORKED WITH OR FOR, JUST AS WITH OTHER SERVICE LINES, WORK DILIGENTLY TO MAKE THE QUALITY OF THEIR PROGRAMS, BASED ON EVIDENCE-BASED PRACTICES AND QUALITY IMPROVEMENT PROCESSES, THE BEST PROGRAMS POSSIBLE. IN THE SCHEME OF THE PRESENT AND FUTURE HOSPITAL FACILITY CULTURE, THE COE IS MERELY ANOTHER WAY TO TAKE MONEY OUT OF THE

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    Pleatman, Mark Title: Bariatric Surgeon
    Organization: Mark A Pleatman MD
    Date: 06/28/2013
    Comment:

    As a bariatric surgeon I support this policy change. I operate out of several hospitals; some are "COE" and some are not. Excellence does not come from filling out paperwork and paying money for certification. These requirements are silly and restrict access to care. Bariatric surgery is no different from any other kind of surgery; Medicare does not require gallbladder surgery to be done at a COE, and it shouldn't have any special certification requirements for bariatric

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    Datta, Tejwant Title: Director, Minimally Invasive and Bariatric Surgery
    Organization: Southside Regional Medical Center
    Date: 06/28/2013
    Comment:

    As a bariatric surgeon, and ASMBS member, in the Petersburg, VA area, I applaud the CMS proposal to remove the COE requirement for Medicare patients. I see a number of patients in the rural community who have a lack of access to a wide variety of medical care. This previous requirement essentially discriminated against rural patients without easy access to metropolitan COE bariatric programs.

    I feel that as an ASMBS, board certified, fellowship trained bariatric surgeon, patient

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    Taylor, Sylvia Title: RN - Manager Bariatrics
    Organization: BHC
    Date: 06/28/2013
    Comment:
    I am in support of this change. We have a high quality Bariatric Program with great outcomes. We have had to turn away many Medicare eligible patients as we were not COE certified. We meet all COE requirements except for volume. Being in a rural area with limited patients having private insurance coverage, it has been difficult to meet the quantity guideline. We are looking forward to being able to provide care to all patients who qualify for surgery. I would also agree that it does not

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    Bowman, Beverly Organization: Community Health System
    Date: 06/27/2013
    Comment:
    Please clarify the plan for coverage of open and laparoscopic sleeve gastrectomy procedure for the purpose of weight loss.
    Weiner, Matthew Title: Owner
    Organization: Matthew Weiner, MD, PLLC
    Date: 06/27/2013
    Comment:

    I applaud this decision and feel that it is consistent with the best interest of my patients. I have a few high risk medicare patients that will be ready for surgery this fall. I've been very concerned about them since they would need to be done at the COE in my hospital system, 45 minutes away.

    This decision will allow me to schedule them at my home institution where I can round on them several times per day and they can be seen by their regular cardiologist and other

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