December 21, 1998

Health Care Financing Administration
Department of Health and Human Services
Attention: HCFA 1913-IFC
P.O. Box 26688
Baltimore, MD 21207-0488

To whom it may concern:

The American College of Chest Physicians (ACCP) has reviewed the interim final regulations of the Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities published in the Federal Register and offers our Respiratory Care Section Position Statement for consideration by HCFA.

ACCP feels that it is important to recognize the unique and qualified nature of the training received by respiratory therapists. Their particular ability to attend to patients with complex respiratory illnesses, especially those unstable patients on ventilators often released from hospitals to skilled nursing facilities, is important to the overall quality of patient care. The one single issue that must be underscored in reviewing this final rule is quality of patient care.

The ACCP is a professional medical specialty society of approximately 15,000 physicians, scientists, allied health professionals, and educators who specialize in diseases of the heart, lungs, and circulatory system. Its members are specialists in pulmonology, cardiology, cardiovascular and cardiothoracic surgery, and critical care medicine.

Sincerely,

Allen I. Goldberg, MD, FCCP
President
American College of Chest Physicians

---