2006 proposed fee schedule - American Society of Clinical Oncology

CMS Review
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As noted previously, consultations are included on the
list of approved telehealth services. However, as a
condition of payment, §410.78 of the regulations requires
the use of an interactive two-way audio and video
telecommunications system to furnish a telehealth
consultation. The use of one-way video does not meet the
current interactive telecommunications system requirements
for telehealth services and, therefore, the requestor cannot
bill for a consultation service based on the model described
above.
We have concerns with modifying our definition of an
interactive telecommunications system to permit one-way
video in place of an interactive two-way video system. The
use of an interactive audio and video telecommunications
system permitting two-way real-time interaction between the
physician or practitioner at the distant site and the
beneficiary and telepresenter (if necessary) at the
originating site is a substitute for the face-to-face
examination requirements of a consultation under Medicare.
We are concerned that the use of one-way video may not
be clinically adequate for the evaluation of certain types
of patients. Since telehealth services are intended as a
substitute for services that traditionally require a
face-to-face interaction between a physician (or