On behalf of the Medical Society of Virginia (MSV), I would like to thank you for the opportunity to comment on this petition. MSV is a professional organization for physicians with approximately 9,000 members. 

 

We are in support of the petition’s request that the radiological materials fee schedules be re-examined and revised so that they do not exceed comparable federal Nuclear Regulatory Commission (NRC) fees. Following implementation of the Virginia fee schedules, we received notice from members indicating that their new fees were substantially higher than the fees they would have paid to the NRC, since they no longer received a “small business” discount. This occurred despite several references in the regulatory promulgation documents assuring that their fees would not increase and would likely actually be reduced after the transition to the Virginia program. The feedback we received suggested that such assurances kept those who were negatively affected by the fees from objecting to the initial proposal.

 

We do not believe that the current fee schedules coincide with intent that the regulations establish equal or reduced fees, so we support that the fees be revised accordingly. Again, we appreciate the opportunity to comment on this matter.

 

Jeff Buthe

Senior Policy Analyst