Seema Verma, MPH 
Administrator 
Centers for Medicare & Medicaid Services 
Attention: CMS-1715-IFC 
P.O. Box 8016 
Baltimore, MD 21244-8016 
RE: Potentially Misvalued Code 
      Request for Non-facility Pricing of CPT Code 49436 
 
 
Dear Ms. Verma, 
 
I am the medical director of the home dialysis program at the University of Colorado. In this capacity, I have performed externalizations of embedded peritoneal dialysis catheters more than 200 times, always- every last one- in the outpatient setting. I have had not a single serious complication. In my opinion it is unequivocally safe to perform this procedure in an outpatient office. Unfortunately, supplies for this procedure are not covered by CMS. This drives many physicians to perform the procedure in the more expensive facility environment. I believe that the use of embedded catheters would increase if physicians didn't have to foot the bill for the supplies.  
 
Thank you very much for your consideration of this matter.  
 
 
Sincerely, 
Isaac Teitelbaum, MD 
Professor of Medicine 
University of Colorado School of Medicine 
 
Mail Stop F774  
12605 E. 16th Avenue | Aurora, Colorado 80045 
p 720- 848- 7601  |  f 720- 848-3103   isaac.teitelbaum@cuanschutz.edu 
 

 
 

 
Isaac Teitelbaum, MD 
Professor of Medicine  
 

