Patients should not be put in a position to make a diagnosis prior to coming to the ED, and hospitals and physicians should not be punished with non-payment/reduced payment when clinical investigation ultimately results in a diagnosis that exists on a downcode list.

Have you read the downcode list?  It includes Pneumonia, Diabetic Ketoacidosis, and Pyelonephritis!!!!  These are potentially deadly diagnoses and represent true emergencies.  

Putting up barriers to access to care and punishing front-line health workers and hospitals, especially critical access hospitals, is not a morally responsible way to balance a budget.

Please halt implementation of this program and let's open up an investigation and conversation on how funds can be conserved while not placing those involved in receiving care and providing care in the middle.

Sincerely,

Ben A. Fickenscher, MD F-ACEP F-AAEM