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JUN 111984 The Honorable Phil Grarrin United States House of Representatives Washington, DC 20515
Dear Congressman Gram:
Thank you for your letter to Mr. Kamerer dated May 18, 1984, on behalf of your constituent, Mr. Bruce W. Hamond, President, Medical Ancillary Services, Inc. Nr. Hamond expressed some concerns about an early draft revision of our regulations governing the medical use of radioactive materials as it pertains to mobile nuclear medicine service companies.
The !!uclear Regulatory Comission staff is currently redraf ting the proposed revision of the medical regulations for the Commissioners' consideration. The staff will take Mr. Hamond's coments under consideration when revising the mobile services sections.
The staff plans to forward the proposed revision to the Comissioners late this sumer.
If the Comissioners approve the proposed revision, it will be published in the Federal Register for public coment.
Thank you for your interest in this matter.
If we can provide further information, please do not hes,itate to contact us.
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Respectfully referred to Please updata me on this proposal and let me know what the NRC plans to do with it. Thank you.
Rep. Phil Gramm 1230 Longworth llouse Bldg.
Washington, D.C. 20515 ATTENTION: John Eavercool l
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The Honorable Phil Gramm D
Representative United States Congress United States Capital Washington, D.C.
20515
Dear Representative Gramm:
Currently there is within the %KC1a propos.ed revision to I
aTEt'-% den,ng.w2.th rn algut.cQv_ejgia.ferials.
If this pro-posed regulation is published and adopted by the NRC changes will have a direct and derogatory effect on the operation of not only our company but other similar providers through-out the country.
MASI is a mobile medical services company.
providing nuclear medicine, ultrasound and C.T. services to small rural hospitals, primarily in the north central Texas area.
For the small rural hospital the mobile service is without a doubt the most efficient way to provide needed patient services.1!T.litepropose%7NsI61/ of f artdryo-dTd ha're F 4Hi ric.nupac.t2on mot-oni -ouroerrices but.those =tfr-The]
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(kniTp 21ejposed2cTan,gI<iA16Z6th 2H5~55iipp. lying unfiE$ @$36E-hisWF mio a criv e m a*.tefifl.;n e_e a.e d t'o7p eff3 hi_tW W:xam3 Presently mobile services are allowed to transport multi dose and single dose vials of radioactive materials both in agreement and non-agreement states.
The proposed change would be to allow only transportation and transfer of single, assigned unit doses.
The problem with this change is that these unit doses would have to be ordered from a nuclear pharmacy or compounded by the technician before leaving the base hospital.
Since they are assigned, no additional patients would be able to be done once we arrive at a hospital.
We would be forced to tell the physician "I'm sorry, we cannot do this patient today, he will have to wait until tomorrow".
This is neither quality medical care nor cost efficient, nor in my opinion, from a radiation safety
. standpoint, is it necessary.
The impact on our business if we are unable to do additional patients during the day from a 9
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'[tholonorablelPh'ilGramm P.epresentative s
April 18, 1984 i
Page 2 financial standpoint is obvious.
The impact on the hospitals is one-that is equally as serious.
and implementation of DRG's, cost Since the passage of TEFRA have become major points in the provision of health care. effectiveness and efficienc i'
This
,wproposed rule would have the effect of increasing the length
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of. stay for an inpatient in.a hospital because we were not allowed to carry an extra dose to perform the examination.
i The reason that this regulation would have such a large effect on the small rural hospital is that as you well know, in the rural areas on the average approximately 60-75% of patients are medicare and in some places this is as high as 85%.
Obviously an extension in the length of stay for an.
l inpatient could be financially devastating to a small hospital.
g Another potential effect this would h, ave on the provision of health care is the inability to perform emergency procedures, as necessary in the field.
In most rural locations the nuclear pharmacy is an hour to two hours away.
This nearest is not very conducive to providing prompt patient care.
If i
it was your relative or my relative that was in need of this care, I would certainly be more than a bit upset if I had to wait to the next day or for the technician to drive two
. hours'ene way and two hours back before he could perform the 1
examination.
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I feel that the present licensing system'is more than adequate l
at to address the radiological safety aspects of the provision of mobile nuclear medicine.
There may be some cases of abuse of p 'the system, however, we should not punish the majority to o
control the minority.
We also need a consistent federal policy.
.g If through TEFRA we are to control costs, we certainly cannot do this if another governmental agency is placing restrictions upon the health care industry that would increase costs.
We f
would appreciate whatever' help you may be able to lend in this matter.
Sin erely,
_ME CAL ANC LLAR SERVICES, INC,
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