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August 17, 2018


Dear Colleagues,


Since my last communication, the California Society of Thoracic Surgeons (CASTS) has been granted an extension to the initial stakeholder comment period. The CASTS leadership has reached out to their members for suggested edits to the current outdated regulations. While there has been some spontaneous requests, from our surgeon colleagues, to change the regulation to allow the use of CTPAs as first assistants, the APACVS Board of Directors and the AAPA/APACVS Title 22 Committee felt that an overwhelming request for change would be beneficial.


Simultaneously, Assembly Bill AB 1225 has passed both the State Assembly and Senate Committees and will be voted on in the near future.

This bill, if it becomes law will require the following:


1) Requires DPH to report to the Legislature by January 1, 2020, on its efforts to update or modernize its regulations under Division 5 of Title 22 of the California Code of Regulations to better reflect modern day best practices and technologies with regard to DPH’s administration of those codes and also its use of program flex waivers. Requires this report to be submitted in compliance with specified requirements in law governing legislative reports.

2) Requires DPH to focus on, an prioritize, adoption of amendments to the following regulations: a) Sections 70435 and 70437 of Title 22 of the California Code of Regulations, related to cardiovascular surgery staff, equipment, and supplies; and, b) Sections 70438, 70438.1, and 70438.2 of Title 22 of the California Code of Regulations, relating to staffing requirements and procedural limitations with cardiac catheterization laboratories.


Ed Razenbach has already started a discussion with Dr. Carey. However, once this task is completed, I will officially reach out to the CASTS Leadership to initiate an official discussion and work with the CASTS Leadership to finally resolve this issue. It is the opinion of the APACVS/AAPA Tile 22 Committee that obtaining CASTS approval PRIOR to the public comment period will significantly increase the chances of a positive outcome.


Attached is a letter to the CASTS Leadership requesting this change. The letter is attached and will also be located on the APACVS website ( with the appropriate instructions for your review.

The instructions are as follows:

  1. Download the form and have each supportive surgeon sign it
  2. Please return it to the following CASTS leadership

               a. Dr. Peyman Benharash (

                b. Dr. Jack Boyd (

                c. Dr. Joesph Carey (

       3. Please notify me that you have sent this in at

The CASTS deadline is 31 AUGUST, so your prompt attention is requested. Please download and send this to the above CASTS leadership ASAP.

Thank you again for your continued membership and support!






Steven M Gottesfeld, PA-C

President, APACVS


To download the CASTS Letter click HERE



To View the All Facilities Letter From the State of California Click HERE 

To view the Sample Letter to CA Surgeons Click HERE 

To Submit Feedback to the State, Download and Complete the Written Comments Form HERE

Email this form to: 

For an Example of How to Complete the Written Comments Form Click HERE 

To view the Directions for Submitting Feedback Click HERE 

To view the APACVS Letter of Endorsement click HERE





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