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August 26, 2009

Centers for Medicare and Medicaid Services
Room 445-G
Hubert H. Humphrey Building
200 Independence Ave SW
Washington D.C. 20201


To Whom It May Concern:

On behalf of the Wound, Ostomy and Continence Nurses Society (WOCN) and the patient population we serve, I am writing to convey our support regarding the current CMS proposal for changes to CMS-1414-P, the Coverage of Outpatient Therapeutic Services Incident to a Physician's Service.

Founded in 1968, WOCN is a professional, international nursing society of more than 4,600 healthcare professionals who are experts in the care of patients with wounds, ostomies and incontinence needs. Our primary goal for quality patient care is to treat individuals in the most cost effective and efficient manner based on sound scientific evidence and proven patient outcomes. Given WOCN's strong focus on patient outcomes, we believe the proposed changes will promote patient safety and high quality care for the Medicare recipients of these services.

WOCN believes the revised language in CMS-1414-P, Coverage of Outpatient Therapeutic Services Incident to a Physician's Service, will improve patient care because it promotes the need for physicians to respond to the hospital outpatient department for patient emergencies, changes in patient condition and staff concerns.

WOCN supports the CMS proposal, which allows direct supervision by nurse practitioners and certified nurse specialists in the hospital outpatient department. We believe this addition supports the ability of our advanced practice wound, ostomy and continence nurse colleagues to directly supervise the hospital outpatient therapeutic services, which they are able to personally perform within their state's scope of practice and hospital-granted privileges.

Finally, WOCN also supports the clarification of "direct supervision” in off-campus hospital outpatient departments. WOCN believes this clarification will provide the appropriate assistance and medical direction to baccalaureate-prepared wound, ostomy and continence nurses working in the hospital outpatient department.

Thank you for your consideration of these comments. Please feel free to contact WOCN should you have any questions regarding the impact of CMS-1414-P on our members and their ability to treat patients with wounds, ostomies and incontinence.


Phyllis Bonham, PhD, MSN, RN, CWOCN, DPNAP
President, WOCN Society

Posted: August 25, 2009
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