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

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19.02.2013 Views

CMS-1403-FC examination, must be made regarding the administration of thrombolytic therapy within 3 hours of the onset of stroke symptoms. The elements of remote stroke assessment involve discrete interactions between physicians and patients, and the consultative input of specialists experienced in acute stroke treatment is considered in directing the bedside care of the patient. Some commenters were concerned that our proposal will not permit the use of telehealth to treat critically ill patients. We received comments and supporting documentation regarding the feasibility and value of providing consultations via telehealth to patients who are critically ill. Response: Consultations are already included on the list of approved telehealth services. Our proposal not to add critical care services (as defined by 99291 and 99292) to the list of Medicare telehealth services does not preclude physicians or NPPs from providing medically necessary and clinically appropriate telehealth consultations to patients who are critically ill. We believe that permitting initial and follow up inpatient consultation via telehealth will help provide greater access to specialty care for critically ill patients (including stroke patients). If guidance or advice is 102

CMS-1403-FC needed regarding a critically ill patient, a consultation may be requested from an appropriate source and may be furnished as a telehealth service. (See the CMS Internet- Only Medicare Claims Processing Manual, Chapter 12, Section 30.6.10 for more information on Medicare policy regarding payment for consultation services.) In support of the request to approve critical care services (as described by HCPCS codes 99291 through 99292), UPMC provided comparative analyses involving the use of an interactive audio and video telecommunications system as a substitute for an in-person (face-to-face) clinical assessment. However, the focus of these studies was limited to stroke patients (critical care services include a broad range of disease categories). Additionally, one study recruited clinically stable patients. This study noted that “because of the subacute nature of our test bed, the current data must be considered preliminary in determining their potential impact on actual clinical decision making.” The same study also noted that although the use of telehealth “may expedite stroke-related decision making, it cannot and should not be thought of as a substitute for the comprehensive clinical evaluation of the acute stroke patient, including thorough medical and 103

<strong>CMS</strong>-1403-FC<br />

examination, must be made regarding the administration of<br />

thrombolytic therapy within 3 hours of the onset of stroke<br />

symptoms. The elements of remote stroke assessment involve<br />

discrete interactions between physicians and patients, and<br />

the consultative input of specialists experienced in acute<br />

stroke treatment is considered in directing the bedside<br />

care of the patient.<br />

Some commenters were concerned that our proposal will<br />

not permit the use of telehealth to treat critically ill<br />

patients. We received comments and supporting<br />

<strong>document</strong>ation regarding the feasibility and value of<br />

providing consultations via telehealth to patients who are<br />

critically ill.<br />

Response: Consultations are already included on the<br />

list of <strong>approved</strong> telehealth services. Our proposal not to<br />

add critical care services (as defined by 99291 and 99292)<br />

to the list of Medicare telehealth services does not<br />

preclude physicians or NPPs from providing medically<br />

necessary and clinically appropriate telehealth<br />

consultations to patients who are critically ill. We<br />

believe that permitting initial and follow up inpatient<br />

consultation via telehealth will help provide greater<br />

access to specialty care for critically ill patients<br />

(including stroke patients). If guidance or advice is<br />

102

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