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Fighting For California PAs
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Dear California Cardiothoracic PA,

I have both excellent news and a request for you. The California Department of Public Health (CDPH) is requesting stakeholder input on a change to specified sections of Title 22. This All Facilities Letter describes sections and process. As you are well aware, we have been working to have this regulation changed for many years. This notice from CDPH is a very good early step. The troublesome section is 70435 (b)(2):

CCR Title 22, Division 5, Article 6, 70435(b)(2):

"A minimum of three surgeons shall constitute a surgical team for the performance of all cardiovascular operative procedures which require extracorporeal bypass. At least one surgeon must meet the requirements outlined in subparagraph (b)(l) above. "

Now, a request from me in two steps:

Step one: Generate Comments to CDPH

It is critical that CDPH hear from a large group of stakeholders who support changing this regulation. I've attached a letter to California cardiothoracic surgeons explaining the issue and asking them to submit their comment using the CDPH form.  Please read this letter, then share it with your surgeons and ask them to submit a comment asking for a change that allows the surgeon to design their team, within the boundaries of the credentialing and privileging process of the facility.

I'm also attaching the language that is up for review, a summary of the issue, and letters of support from stakeholder organizations, including AATS and STS.  

Please take steps now to assure that we have comments from surgeons to support removal of this archaic requirement. This notice was sent to all hospitals, so please also encourage your facility leadership to comment. Please use the Written Comments Form to submit comments yourself.  Instructions and sample ideas are at the end of the "Dear Surgeon" letter.

Step two: Report Back

APACVS needs to know what stakeholders are responding and what they are saying. Please forward these to me at

APACVS is working in partnership with AAPA on this effort and we have one week to make an impression. Thanks for taking time to make this happen. I look forward to hearing from you with any questions or concerns, and to hear what impact you are generating.

Thanks for your assistance and membership!

Steven M Gottesfeld, PA-C

President, APACVS



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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