Fwd: Re: NRC Information Notice 2002-28

["Carol S. Marcus" <csmarcus@ucla.edu>]

> Date: Fri, 04 Oct 2002 08:39:09
>
> -0700
>
> To: William V Lipton <liptonw@dteenergy.com>
>
> From: "Carol S. Marcus" <csmarcus@ucla.edu>
>
> Subject: Re: NRC Information Notice 2002-28
>
>
> At 09:14 AM 10/4/02 -0400, you wrote:
>
> >   
> >
> >
> > "Carol S. Marcus" wrote: 
> >
> > >   
> > >
> > > Dear Mr. Lipton: 
> > >
> > >
> > > You need to learn to make a distinction between board certified
> > >
> > > physicians in Nuclear Medicine, as opposed to other groups of physicians
> > >
> > > who have little education or training in Nuclear Medicine, but who manage
> > >
> > > to buy licenses to practice some or all of it because NRC is desperate
> > >
> > > for the money from the User Fees.  The United States has the lowest
> > >
> > > requirements for practicing Nuclear Medicine among first world countries,
> > >
> > > and has lower requirements than many third world countries as well, such
> > >
> > > as India.  I think that you will find that the poor quality
> > >
> > > professional behavior "discovered" by the NRC is not occurring
> > >
> > > to any extent, or certainly any significant extent, among the board
> > >
> > > certified Nuclear Medicine physicians, but among others with lesser
> > >
> > > qualifications.  This is certainly the case with NRC's
> > >
> > > "misadministrations", nearly all of which occurred in practices
> > >
> > > of non-board certified Nuclear Medicine physicians.  The few that
> > >
> > > occurred with board-certified Nuclear Medicine physicians were almost
> > >
> > > invariably caused by techs who disobeyed procedures put in place by the
> > >
> > > physicians.  The real lesson is that NRC is inflicting poor quality
> > >
> > > Nuclear Medicine on members of the public because (1) NRC needs the money
> > >
> > > and (2) NRC advertises medical shortcomings and errors perpetrated by
> > >
> > > such poorly educated and trained individuals as evidence for the need of
> > >
> > > its regulation of the field, fooling naive members of the public,
> > >
> > > Congress, and apparently you as well.  One could easily look at
> > >
> > > NRC's "discoveries" and come to quite another conclusion,
> > >
> > > namely, that NRC has caused a problem by selling licenses to poorly
> > >
> > > qualified individuals, and that it should proceed to require the
> > >
> > > education, training, and experience of physicians for its own licensing
> > >
> > > that the American Board of Nuclear Medicine requires for its
> > >
> > > Diplomates.  That is what NRC has done with Radiation
> > >
> > > Oncology.  Why not Nuclear Medicine? 
> > >
> > >
> > > That would solve most of NRC's "problems", but the drop in
> > >
> > > User Fee income would cause NRC to have to unbudget many of its staff and
> > >
> > > management, all of whom are completely incompetent in Nuclear Medicine,
> > >
> > > or any kind of medicine, and Nuclear Pharmacy, or any kind of pharmacy,
> > >
> > > not to mention its pathetic competence in medical physics and
> > >
> > > mathematics. 
> > >
> > >
> > > When the National Academy of Sciences-Institute of Medicine studied
> > >
> > > NRC's "medical" program, the NAS-IOM found that it was so
> > >
> > > dysfunctional and without value that it recommended that Congress remove
> > >
> > > NRC's statutory authority in all medical and medical research areas. Way
> > >
> > > to go, guys............... 
> > >
> > >
> > > If you need a Nuclear Medicine procedure, what do you look for? 
> > >
> > > A physician board certified in Nuclear Medicine, or any old physician who
> > >
> > > has bought a license to practice it from a greedy, medically incompetent
> > >
> > > regulator? 
> > >
> > >
> > > Ciao, 
> > >
> > >
> > > Carol S. Marcus, Ph.D., M.D., ABNM, FACNP 
> > >
> > >
> > > <csmarcus@ucla.edu>
> >
> >
> >
> > Dear Dr. Marcus, 
> >
> >
> > Many thanx for supporting my opinion that medical licensees need to
> >
> > improve their self -regulation.  It seems, however, that you are
> >
> > confusing the practice of nuclear medicine with the practice of health
> >
> > physics.  A  hospital RSO's responsibilities are quite
> >
> > different from those of  a nuclear medicine physician, even though
> >
> > they could be the same individual.  I find it difficult to
> >
> > understand how a hospital RSO, even if board certified in nuclear
> >
> > medicine, could fulfill his responsibilities if he's not even aware that
> >
> > he's the RSO. 
> >
> >
> > The opinions expressed are strictly mine. 
> >
> > It's not about dose, it's about trust. 
> >
> > Curies forever. 
> >
> >
> > Bill Lipton, Sc.D., CHP, CHMM, MBA 
> >
> > liptonw@dteenergy.com 
> >
> >   
> >
> >   
> >
> >   
>
>
>
> Dear Bill:
>
>
> You missed the point.  These are not board-certified nukes who are
>
> made RSO's without their knowledge.  These are generally diagnostic
>
> radiologists.
>
>
> In addition, the non-medical job of an RSO in a community hospital that
>
> does some nuclear medicine is largely secretarial, and has no safety
>
> significance at all.  The job is to produce paper for inspectors to
>
> inspect.  The real job is nuclear medicine practice,
>
> which is often poor, practiced by techs who are incompetent to practice
>
> any kind of medicine.  
>
>
> In medicine, as in anything else, there is a whole spectrum of quality of
>
> practice.  Only the real outliers on the bottom end are not
>
> tolerated.  NRC purports to keep things to a higher standard, and
>
> chop off the low end.  This was the case for many years. 
>
> However, when NRC started having to raise all its operating expenses with
>
> User Fees, around 1990, it got onto this racket of licensing docs to do
>
> pieces of nuclear medicine, chopping up a practice so as to leave little
>
> for a board certified nuke, and the specialty is shrinking thanks to
>
> NRC.  However the number of licenses stays
>
> artificially high.  It tried to do this with Radiation Oncology at
>
> the last rulemaking, but was politically fought down.  
>
>
> The NRC is not succeeding in making the quality of Nuclear Medicine
>
> better.  It is making it worse.  If we had no NRC regulation,
>
> Nuclear Medicine would be practiced like any other kind of medicine, and
>
> patients would choose board-certified Nuclear Medicine docs for good
>
> quality studies or procedures.  Most members of the public are
>
> fooled into thinking that if you have an NRC (or Agreement State)
>
> license, that is equivalent to "competence".  Totally
>
> untrue.
>
>
> As to your allegation that medicine needs to reform itself, you obviously
>
> have no idea what is going on.  Due to HCFA (now CMS) reimbursement
>
> fraud, happily picked up by many third party payors, many hospitals and
>
> medical practices are going under.  The economic underpinning of a
>
> healthy medical profession has had the bottom fall out.  Hospitals
>
> and medical practices are doing what they need to do to survive. 
>
> Getting rid of specialists and telling other docs to pick up that work is
>
> going on all over medicine for survival.  Endocrinologists are
>
> kicked out and internists and family practice guys are told to take over
>
> the endocrine cases.  Dermatologists are cut out and family practice
>
> docs are told to take it over.   In some HMO's, getting to see
>
> a specialist takes an act of Congress.  University medical centers
>
> at medical schools, which used to provide highly complex, specialized
>
> care for small numbers of patients, and acted as a professional resource
>
> for physicians in a geographic area, are now vying with physicians in
>
> private practice to grab up insured patients, and screwing the private
>
> docs.  Without this, medical schools would go under because the
>
> increased reimbursement that contributed significantly to medical
>
> teaching institutions largely disappeared. 
>
>
> This situation is not medicine's problem.  It is the nation's
>
> problem, because our government created the mess in an attempt to
>
> decrease the cost of medical care.  
>
>
> You can always make something cheaper by making it crummier.  If you
>
> think that there should be some minimum standards in some fields, such as
>
> medicine, and teaching, and engineering, etc., I assure you that
>
> government is the last place to do this.  You only generate a bunch
>
> of bureaucrats who care only about job preservation.  NRC adds huge
>
> costs to Nuclear Medicine, adds NO safety, and decreases the
>
> quality.  At the last Part 35 rulemaking meeting at White Flint when
>
> this abortion started a few years ago, two representatives from CMS came
>
> to the meeting and told NRC flat out that they would not reimburse for
>
> costs generated by the rulemaking.  NRC did not give a rat's
>
> ass.   NRC is now contributing to the cost problem by making it
>
> more and more expensive to practice Nuclear medicine in an environment of
>
> decreasing reimbursement, and most nuclear medicine today is practiced as
>
> part of a general radiology practice and the nuclear medicine
>
> "losses" are balanced by huge profits in other parts of
>
> Radiology.  Other docs choose to do only the nuclear medicine
>
> procedures that pay reasonably well, "cherry picking" from the
>
> panoply of over a hundred possible procedures, many of which lose money
>
> for the practitioner.  In many cases, your drugs are not even
>
> reimbursed, and your hospital will not permit you to even perform the
>
> procedure, and patient be damned.
>
>
> Ciao, Carol