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CMS-1403-FC
Medicare telehealth services. The skill-based training
involved in teaching beneficiaries the skills necessary for
the self-administration of injectable drugs is a key
component of this statutorily defined benefit (and therefore
inherent in the codes that describe DSMT). We do not
believe that it would be appropriate to carve out this
statutorily required component of DSMT for purposes of
telehealth.
b. Critical Care Services
The (UPMC) submitted a request to add critical care
services (as defined by HCPCS codes 99291 and 99292) as a
“Category 1” service. The requester draws similarities to
the evaluation and management (E/M) consultation services
currently approved for telehealth. The requester noted
that the primary difference between critical care and other
E/M services already approved for telehealth is that
critical care is specific to patients with vital organ
failure. Anecdotally, UPMC has found that the use of
telecommunications systems and software gives stroke
patients timely access to highly specialized physicians.
According to the request, UPMC physicians are able to give
“an equally effective examination, spend the same amount of
time with the patient and develop the same course of
treatment just as if they were bedside.”
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