2006 proposed fee schedule - American Society of Clinical Oncology

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furnished in the group setting and, as explained above, we
believe group therapy has a different interactive dynamic
than the current list of Medicare telehealth services.
Additionally, the statute requires the training content for
DSMT to include teaching beneficiaries the skills necessary
for the self-administration of injectable drugs. We
question the merits of providing beneficiary training to
administer insulin injections via telehealth. For example,
teaching a patient how to inject insulin requires
consideration and instruction regarding factors such as the
type of needle to be used, the anatomic location of the
injection, the injection technique, and possible
complications of the injection, all of which we believe,
absent evidence to the contrary, require the physical
presence of the teaching practitioner.
These components are typically not part of the services
currently on the list of telehealth services and the
requestor did not provide any comparative analyses
illustrating that the use of a telecommunications system is
an adequate substitute for the in-person, collaborative,
skill-based training required for DSMT services. Therefore,
we propose to not add DSMT (as described by HCPCS codes
G0108 and G0109) to the list of Medicare telehealth
services.