Notice: This CMS-approved document has been submitted - Philips ...

CMS-1403-FC
The acuity of a critical care patient is significantly
greater than the acuity generally associated with patients
receiving the E/M services approved for telehealth.
Because of the acuity of critically ill patients, we do not
consider critical care services similar to any services on
the current list of Medicare telehealth services.
Therefore, we believe critical care must be evaluated as a
Category 2 service.
Because we consider critical care services to be
Category 2, we needed to evaluate whether these are
services for which telehealth can be an adequate substitute
for a face-to-face encounter. We had no evidence
suggesting that the use of telehealth could be a reasonable
surrogate for the face-to-face delivery of this type of
care. As such, we did not propose to add critical care
services (as defined by HCPCS codes 99291 and 99292) to the
list of approved telehealth services.
Comment: UPMC submitted a detailed description of
their experiences using telehealth to support the treatment
of acute stroke patients and provided supporting studies
describing the use of telemedicine in remote stroke
assessment. Per their comment, remote stroke assessment
has specific and unique clinical importance because an
urgent decision, based in part on a neurological
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