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ACS Advocacy and Health Policy Staff Interim Director Assistant Director, Regulatory Affairs and Quality Improvement Programs Manager, State Affairs General Information |
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The value of implementing trauma systems through statewide planning has been recognized, and it has already been demonstrated that these organized regional systems result in dramatic improvements in patient outcomes. Unfortunately, in some situations, managed care systems or insurers have interfered with and defeated the purpose of trauma systems by not authorizing treatment without prior authorization, by denying payment, or by requiring the transfer of trauma patients to providers with whom they have entered into contracts. The College believes that managed care plans and insurers should be required to allow their patients to be treated in trauma centers or emergency facilities when true medical emergencies arise. Managed care plans and insurers should coordinate efforts and reach agreement with trauma centers to assure that there is prompt access to and proper reimbursement for trauma care, as well as free exchange of performance data and mechanisms for resolving conflicts.
ACS Statement on Trauma System Development
The Honorable Hal Stratton
Chairman
The Honorable Thomas Moore
Vice Chairman
U.S. Consumer Product Safety Commission
Washington, DC 20207
Dear Chairman Stratton and Vice Chairman Moore:
As pediatricians, trauma surgeons, nurses and other medical professionals, we urge you to reject the Commission's staff recommendation to deny the petition from Consumer Federation of America et. al. requesting a national safety standard barring the sale of adult-size all-terrain vehicles (ATVs) for use by children under age 16. Our daily experiences in emergency, operating and examining rooms nationwide as well as years of peer-reviewed research demonstrate that these children do not have the range of physical, cognitive and developmental skills necessary to safely operate these powerful motor vehicles. We believe that a federal rule issued by the Commission is an integral part of a more comprehensive effort to improve ATV safety, including aggressive education, enactment of state laws, and increased parental involvement.
The Commission is well-aware of the significant body of epidemiological research documenting the rising toll that adult-size ATVs take on our children in terms of serious injuries and deaths. Moreover, as the Commission's staff appropriately acknowledges in its recommendation, ATV-related injuries are more severe than those caused by any other form of recreation or sport in which children routinely participate based on hospitalization rates per thousand participants.1 In light of these consistent and long-term findings, major national medical organizations, including the American Academy of Pediatrics and the American Academy of Orthopaedic Surgeons, have adopted formal policies and positions recommending that children under 16 years old not drive ATVs.
We are concerned that the staff's recommendation overall deemphasizes the significant public health and monetary benefits that could be achieved with a national standard, including the fact that moving children from adult-size ATVs to youth models could cut the risk of serious injury and death in half. Instead, staff focus on costs that can not be quantified and appear relatively minor when compared to the benefits associated with reducing serious injuries and fatalities. Furthermore, we question how the staff can effectively propose to continue to rely on industry's approach to safety when the Commission has documented significant dealer noncompliance with manufacturers' voluntary agreement not to recommend the sale of adult-size ATVs for use by children.
With these issues in mind, we urge you to reject staff's recommendation and move forward to develop a regulation prohibiting the sale of adult-size ATVs for use by children under age 16. In light of the serious and persistent nature of this public health problem, issuing a strong regulation would help to improve industry and dealer accountability and parental responsibility. This regulation would also be an important component of a comprehensive approach to this issue. We are committed to working with the Commission and others to develop and implement this approach on behalf of our patients and every child.
Thank you for considering our views. If you or your staff would like to discuss this issue in more detail, please feel free to contact any of us. Affiliations listed below are for identification purposes only.
Sincerely,
Dr. Phyllis Agran, MD, MPH
Dr. Mary Aitken, MD, MPH
Associate Professor of Pediatrics
University of Arkansas for Medical Sciences
Dr. Diana Alexander, MD
Pediatrician
Franklin Square Hospital
Baltimore, MD
Peggy Allen, RN, BSN
Nurse Educator, Community Outreach
Project Director
Barren County Safe Communities
Glasgow, KY
Dr. Karen Armitage, MD, FAAP
Pediatrician and Public Health Physician
Santa Fe, NM
Dr. Barbara Barlow, MD
Executive National Director
Injury Free Coalition for Kids
New York, NY
Ryan Barrett
Program Coordinator
Injury Free Coalition for Kids of Salt Lake City
Dr. Carl Baum, MD, FAAP, FACMT
Center for Children's Environmental Toxicology
Yale-New Haven Children's Hospital
Dr. Julia Belkowitz, MD
Voluntary Assistant Professor of Pediatrics
Injury Free Coalition for Kids of Miami
University of Miami
Dr. Andrew C. Bernard, MD
Assistant Professor of Surgery
University of Kentucky Hospital Trauma Center
Dr. Clay Bordley, MD, MPH
Associate Professor of Pediatrics
Division of Emergency Medicine
Director, Pediatric Hospitalist Program
Duke University
Dr. William E. Boyle, MD
Professor of Pediatrics and Community and Family Medicine
Dartmouth Medical School
Chairman, Committee on Injury and Poison Prevention (1991-1995)
American Academy of Pediatrics
Dr. Anne Brayer, MD
Assistant Professor, Pediatric Emergency Medicine
University of Rochester
Golisano Children's Hospital
Rochester, NY
Dr. Jeffrey W. Britton, MD, FAAP
Co-Chair, Committee on Injury and Poison Prevention
Wisconsin Chapter, American Academy of Pediatrics
Dr. Julie Brown, MD, MPH
Pediatric Emergency Medicine
Children's Hospital and Regional Medical Center
Seattle, WA
Dr. Marilyn J. Bull, MD, FAAP
Morris Green Professor of Pediatrics
Director, Developmental Pediatrics
Riley Hospital for Children
Indianapolis, IN
Dr. Richard Lee Byrd, MD
Chief of Pediatrics
Kelsey-Seybold Clinic
Houston, TX
Dr. Deborah Callanan, MD, FACEP, FAAP
CHRISTUS Santa Rosa Children's Hospital
San Antonio, TX
Arlethea D. Campbell, RN
Houston, TX
Dr. Carolyn B. Carlson, MD, PhD, FAAP
Pediatrician
Kelsey-Seybold Clinic
Houston, TX
LesleyAnn Carlson, RN, MS
Director, Emergency Services
San Diego Children's Hospital
Dr. Marcel J. Casavant, MD, FACEP, FACMT
Emergency Medicine Physician
Children's Hospital
Columbus, OH
Dr. Susan Lee Chan, MD
Pediatric Emergency Medicine Attending
Long Island Jewish Medical Center
Dr. Jennifer Chapman, MD
Assistant Professor of Pediatrics
Columbus Children's Hospital
Ohio State University
Dr. Lynn Cimpello, MD
Assistant Professor, Pediatric Emergency Medicine
University of Rochester
Golisano Children's Hospital
Rochester, NY
Susan A. Cox, RN, MS, CEN
Director of Trauma Service
San Diego Children's Hospital
Dr. Natalie Cvijanovich, MD
Associate Physician
Division of Critical Care
Children's Hospital Oakland
Oakland, CA
Dr. Walter Dehority, MD
First Choice Community Healthcare
Albuquerque, NM
Dr. Margaret Dolan, MD, FAAP
Susan Douglass
Administrative Director, Child Health and Safety Awareness
Injury Free Coalition for Kids of San Antonio
Safe Kids Coalition of San Antonio
Dr. Susan Duthie, MD
Pediatric Intensivist
San Diego Children's Hospital
Dr. Paul D. Edwards, MD
Shriners Hospital, Plastic Surgery
Harvard University
Dr. James Eusebio, MD, FAAP
Davis, CA
Dr. Mary E. Fallat, MD
Chief of Surgery and Trauma
Kosair Children's Hospital
Professor of Surgery
Division of Pediatric Surgery
University of Louisville
Cheri Fidler, MEd
Director, Center for Healthier Communities
San Diego Children's Hospital
Dr. Jami D. Frost, MD
Associate Professor, Pediatrics
University of New Mexico
Dr. Barbara A. Gaines, MD
Director of Trauma and Injury Prevention Children's Hospital of Pittsburgh
Assistant Professor of Surgery
University of Pittsburgh.
Dr. Madelyn Garcia, MD
Fellow, Pediatric Emergency Department
University of Rochester
Golisano Children's Hospital
Rochester, NY
Dr. H. Garry Gardner, MD
Darien, IL
Dr. Karen Gelfand, MD
Member, American Academy of Pediatrics
Farmington, NM
Dr. Barry Gilmore, MD, FAAP
Medical Director of Emergency Services
Assistant Professor of Pediatrics
University of Tennessee College of Medicine
Dr. Michael Gittelman, MD
Assistant Professor of Clinic Pediatrics
Cincinnati Children's Hospital Medical Center
Dr. John Golestan, MD, FAAP
Director, Pediatric Emergency Medicine
Mercy Hospital of Pittsburgh
Dr. Carol Green, MD
Kelsey-Seybold Clinic
Houston, TX
Dr. Jonathan I. Groner, MD
Trauma Medical Director
Children's Hospital of Columbus
Clinical Associate Professor of Surgery
Ohio State University College of Medicine and Public Health
Dr. John W. Hafner, MD, FACEP
Clinical Assistant Professor of Surgery - Emergency Medicine
University of Illinois College of Medicine at Peoria
Attending Physician
OSF Saint Francis Medical Center
Department of Emergency Medicine
Peoria, IL
Dr. Martin I. Herman, MD, FAAP, FACEP
Assistant Director Emergency Services
Lebonheur Children's Medical Center
Associate Professor Pediatrics
Division Critical Care and Emergency Services
University of Tennessee College of Medicine
Dr. Bob Hickey, MD
Division of Pediatric Emergency Medicine
Children's Hospital of Pittsburgh
Judith Hirschfeld, BS
Passenger Safety Program Specialist
Children's Hospital Trauma Program
Columbus, OH
Dr. Benjamin Hoffman, MD, FAAP
Assistant Professor
Director, Pediatric Residency Program
Department of Pediatrics
University of New Mexico
Vicki Hunter, RN, MSN, CNS
Kelsey-Seybold Clinic
Houston, TX
Dr. Stanley H. Inkelis, MD
Director, Pediatric Emergency Medicine
Harbor-UCLA Medical Center
Professor of Pediatrics
David Geffen School of Medicine at UCLA
Dr. Henry J. Iwinski Jr., MD
Associate Professor of Orthopaedic Surgery
University of Kentucky
Assistant Chief of Staff Shriners Hospital for Children
Sally Jacko, RN, MPH
Deputy Director
Injury Free Coalition for Kids
New York, NY
Dr. David Jaffe, MD
Washington University School of Medicine
St. Louis, MO
Dr. Alan Johnson, MD
Pediatric Emergency Medicine
Children's Hospital and Research Center at Oakland
Oakland, CA
Dr. Carden Johnston, MD, FAAP, FRCP
Birmingham, AL
Kristi K. Kangas, MPH, MSW
Community Coordinator
Injury Prevention Program
Emergency Services
Children's Hospital Boston
Injury Free Coalition for Kids
Pam Kavanagh, RN
Midland Park, NJ
Dr. Karen R. Kingry, MD
Medical Director, Pediatric Programs
Chair of Pediatrics
Suburban Hospital
Bethesda, MD
Dr. Jane Knapp, MD
Injury Free Coalition for Kids
Dr. Abigail Klemsz, MD
Riley Hospital for Children
Indianapolis, IN
Dr. Robert L. Kriel, MD
Hennepin County Medical Center (MN)
Dr. Giorgio Kulp, MD, FAAP
Pediatrician
Metropolitan Pediatrics, LLC
Montgomery County, MD
Dr. Lois Lee, MD, MPH
Director of Trauma Research
Division of Emergency Medicine
Children's Hospital Boston
Dr. Michael Levy, MD
Chief, Neurosurgery
San Diego Children's Hospital
Dr. James G. Linakis, PhD, MD
Associate Professor of Emergency Medicine & Pediatrics
Brown Medical School
Associate Director, Pediatric Emergency Medicine
Hasbro Children's Hospital/Rhode Island Hospital
Dr. Jan Loeffler, MD
Valdosta, GA
Dr. Barry E. LoSasso, MD, FACS
Trauma Medical Director
San Diego Children's Hospital
Dr. Melinda Lucas, MD, FAAP
Maryville, TN
Dr. Merlene McAlevy, MD, FAAP
Kelsey-Seybold West Clinic
Houston, TX
Dr. Constance McAneney, MD
Associate Director, Division of Emergency Medicine
Cincinnati Children's Hospital Medical Center
Dr. Kevan McCarten-Gibbs, MD
Department of Emergency Medicine
Children's Hospital Oakland
Oakland, CA
Dr. R. Ian McCaslin, MD, FACEP
Director, Emergency Medicine
San Diego Children's Hospital
Dr. Celeste Madden, MD
Syracuse, NY
Dr. Mark S. Mannenbach, MD
Division Head
Pediatric Emergency Medicine
Mayo Clinic
Rochester, MN
Dr. Nelly Ann Marcano, MD, FAAP, FACEP
University Community Hospital
Tampa, FL
Dr. Melissa Mason, MD, FAAP Albuquerque, NM
Melinda Mast
Executive Director
Brain Injury Association of Kentucky
Beverly Miller, MEd
Coordinator, Center for Health Promotion
Department of Pediatrics
University of Arkansas for Health Promotion
Dr. David P. Mooney, MD
Director, Trauma Program
Children's Hospital Boston
Dr. Melanie Mouzoon, MD, FAAP
Pediatric Hospitalist
Kelsey-Seybold Clinic
Houston, TX
Hope Mullins
Project Coordinator
Injury Free Coalition for Kids
University of Arkansas for Medical Sciences
Dr. Gene Nathan, MD
Past President
American Academy of Pediatrics, Chapter 3
San Diego, CA
Dr. Doug Nelson, MD
Associate Professor of Pediatrics
Associate Chief, Pediatric Emergency Medicine Primary
Children's Medical Center
University of Utah
Dr. Eliot W. Nelson, MD
Professor of Pediatrics
University of Vermont College of Medicine
Attending Pediatrician
Vermont Children's Hospital
Dr. Michael Ng, M.D.
Staff Pediatrician
Presbyterian Healthcare Services Albuquerque, NM
Dr. Joseph O'Neil, MD
Riley Hospital for Children
Indiana University School of Medicine
Donna Parnell, RN, MNSc
Trauma Program Coordinator
Arkansas Children's Hospital
Dr. Robert F. Patterson, MD, FAAP
Department of Pediatric Critical Care
Nemours Children's Clinic
Pensacola, FL
Dr. Richard H. Pearl, MD, FAAP, FACS
Professor of Surgery and Pediatrics
University of Illinois College of Medicine at Peoria
Surgeon-in-Chief
The Children's Hospital of Illinois
Peoria, IL
Dr. John R. Pederson, MD
Pediatric Hospitalist
Presbyterian Hospital
Albuquerque, NM
Dr. Victor Perez, MD, MPH, FAAP
Assistant Professor of Pediatrics
UCLA School of Medicine
Dr. Shannon Connor Phillips, MD, FAAP
Director, Pediatric Hospitalist Program
The Children's Hospital at The Cleveland Clinic
Melissa Pickle, RN
Pediatric Coordinator
Kelsey-Seybold Clinic
Houston, TX
Dr. Anthony Pohlgeers, MD
Assistant Medical Director
Pediatric Emergency Medicine
Wolfson Children's Hospital
Jacksonville, FL
Dr. Susan H. Pollack, MD, FAAP, PI
Injury Free Coalition for Kids of Lexington
Assistant Professor, Departments of Pediatrics and Preventive Medicine
Kentucky Injury Prevention and Research Center
University of Kentucky
Dr. Wendy J. Pomerantz, MD, MS
Co-Director, Injury Free Coalition of Greater Cincinnati
Cincinnati Children's Hospital Medical Center
Dr. Albert C. Price, MD
Senior Advisor
Lancaster County (PA) Safe Kids
Dr. Tara S. Ramsay, MD, MPH
Kelsey-Seybold Clinic
Houston, TX
Dr. Nikita Rangwalla, MD
Pediatric Emergency Medicine
Children's Hospital of Atlanta at Scottish Rite
Dr. John Ratmeyer, MD, FAAP
Deputy Chief of Pediatrics
Medical Consultant to the Child Protection Team
Gallup Indian Medical Center
Gallup, NM
Dr. Gadi Revivo, MD
Rehabilitation Medical Director
San Diego Children's Hospital
Richard Ricciardi, MSN, CPNP
President
National Association of Pediatric Nurse Practioners
Dr. George C. Rodgers, Jr., MD, PhD
Professor of Pediatrics
University of Louisville
Dr. Steven G. Rothrock, MD, FACEP, FAAP
Emergency Medicine/Pediatric Emergency Medicine
Orlando Regional Medical Center
Dr. Thomas R. Russell, MD, FASC
Executive Director
American College of Surgeons
Blair Sadler
President and CEO
Children's Hospital and Health Center
San Diego, CA
Estella Saenz, MA
Kelsey-Seybold Clinic
Houston, TX
Dr. Richard A. Saladino, MD
Chief, Division of Pediatric Emergency Medicine
Children's Hospital of Pittsburgh
Associate Professor of Pediatrics
University of Pittsburgh School of Medicine
Dr. Julie Sanchez, MD
Pediatric Surgeon
Lead Physician, Injury Free Coalition for Kids of Austin
Children's Hospital of Austin
Austin, TX
Dr. L. R. "Tres" Scherer, III, MD
Principle Investigator, Indianapolis Injury Free Kids Coalition at Riley Hospital for Children
Chair, Indiana Committee on Trauma
Dr. Richard M. Schwend, MD
Associate Professor, University of New Mexico
Chief, Division of Pediatric Orthopaedics
Carrie Tingley Hospital
Albuquerque, NM
Dr. Robert Sege, MD, PhD
Chief, Division of General Pediatrics and Adolescent Medicine
Director, Pediatric and Adolescent Health Research Center
Tufts-New England Medical Center
Ben Selassie, MSW, MPH, ACSW, LCSW
Project Administrator
Injury Free Coalition for Kids-Baltimore
Johns Hopkins Children's Center
Dr. Karen Sheehan, MD, MPH
Children's Memorial Hospital
Chicago, IL
Dr. Frederick C. Sherman, MD
Medical Director, Carrie Tingley Hospital
Professor of Orthopaedic Surgery & Pediatrics
Department of Orthopaedics & Rehabilitation
Department of Pediatrics
University of New Mexico School of Medicine
Dr. Benjamin K. Silverman, MD
Attending Pediatrician
Emergency Department
Professor of Pediatrics
Harbor/UCLA School of Medicine
Children's Hospital of Orange County (CA)
Dr. Morey Silverman, MD
Co-Director, Pediatric Emergency Medicine
Christus Santa Rosa Children's Hospital
San Antonio, TX
Dr. Gary Smith, MD
Director, Center for Injury Research and Policy
Columbus Children's Hospital
Dr. Gilbert A. Smith, MD
Colbert, WA
Gayane Stepanian
Director of Community Affairs
Injury Free Coalition for Kids - Miami
University of Miami/Jackson Memorial Medical Center
Dr. William Storo, MD
Chairman, Department of Pediatrics
Dartmouth Hitchcock Concord
Concord, NH
Dr. Vish Talwalkar, MD
Assistant Professor
Shriners Hospital for Children
University of Kentucky
Department of Orthopaedic Surgery
Dr. Robert R. Tanz, MD
Immediate Past-Chair, Section on Injury and Poison Prevention
American Academy of Pediatrics
Professor of Pediatrics
Northwestern University
Feinberg School of Medicine
Dr. David M. Tolo, MD, FAAP, PEM
Medical Director, Children's Emergency Services
Children's Hospital
Omaha, NE
Dr. Susan B. Tully, MD
Professor Emerita, Pediatrics
David Geffin School of Medicine at UCLA
Consulting Pediatrician
Olive View - UCLA Medical Center
Melanie Tyner-Wilson, MS
Special Needs and Early Childhood Outreach
Injury Free Coalition for Kids-Lexington
Kentucky Injury Prevention and Research Center
Dr. Jeffrey S. Upperman, MD
Assistant Professor of Surgery
Department of Pediatric Surgery
Children's Hospital of Pittsburgh
Chris Vitale, RN, MSN
Injury Prevention Coordinator
Department of Trauma
Children's Hospital of Pittsburgh
Robin S. Voss, RN, MHA, BS, TNCC-I
President
National Association of Orthopaedic Nurses
Dr. Gary Wasserman, DO
Chief, Section Medical Toxicology
Children's Mercy Hospitals and Clinics
Kansas City, MO
Dr. Andrea B. Weaver, MD
Advanced Pediatrics
Vienna, VA
Dr. Lucy I. Weinstein, MD, MPH
Director, Injury Prevention and Control
Winthrop University Hospital
Mineola, NY
Dr. Jeffrey Weiss, MD
Section Head, General Pediatrics
Medical Director, Injury Prevention Center
Phoenix Children's Hospital
Dr. James A. Wilde MD, FAAP
Associate Professor of Pediatrics and Emergency Medicine Section Chief Pediatric Emergency Medicine Research Director
Department of Emergency Medicine
Medical College of Georgia
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Revised March 17, 2005
ACS Views on Legislative, Regulatory, and Other Issues
