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CMS-1403-FC cardiac evaluations.” In another study submitted, the patients selected were not randomized. Comment: A few commenters supported our proposal not to add critical care services to the list of Medicare approved telehealth services. The commenters believe that, within the current standards of practice, critical care services require the physical presence of the physician rendering the critical care services. We received approximately 20 comments expressing opposition to our proposal not to add critical care services to the list of Medicare approved telehealth services which distinguished between their use of telehealth for critical care services and the use of telehealth for remote stroke assessments, as described in the original request. Many of the commenters characterized our proposal as a “non-coverage determination” of remote critical care services and described an intensive care unit (ICU) model that integrates continuous surveillance of the ICU with an electronic medical records interface. This model is also programmed to automatically prompt the physician to rapidly respond and intervene in the event of certain changes in a patient’s physiological status. Many of these commenters included documentation and references to studies that the adoption of this model reduced medical 104

CMS-1403-FC errors; enhanced patient safety; reduced complications; decreased overall length of stay in the ICU; and resulted in a statistically significant decrease in ICU mortality in comparison to the traditional ICU model. The commenters also noted that patient outcomes have been equivalent if not superior to patient outcomes prior to adopting this model of care. The American Medical Association (AMA) recently developed Category III tracking codes for remote critical care services (0188T-0189T). Two specialty societies commented that they are working with other critical care organizations to collect and analyze data on remote critical care services, as requested by the CPT editorial panel. Response: In the CY 2009 PFS proposed rule, we explained that we have no evidence suggesting that the use of telehealth could be a reasonable surrogate for the face-to-face delivery of critical care services, as defined by HCPCS codes 99291 and 99292. We agree with the comments that, within the current standards of practice, critical care services require the physical presence of the physician rendering the critical care services. Our proposal not to add critical care services to the list of approved telehealth services for Medicare was in no 105

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

cardiac evaluations.” In another study <strong>submitted</strong>, the<br />

patients selected were not randomized.<br />

Comment: A few commenters supported our proposal not<br />

to add critical care services to the list of Medicare<br />

<strong>approved</strong> telehealth services. The commenters believe that,<br />

within the current standards of practice, critical care<br />

services require the physical presence of the physician<br />

rendering the critical care services.<br />

We received approximately 20 comments expressing<br />

opposition to our proposal not to add critical care<br />

services to the list of Medicare <strong>approved</strong> telehealth<br />

services which distinguished between their use of<br />

telehealth for critical care services and the use of<br />

telehealth for remote stroke assessments, as described in<br />

the original request. Many of the commenters characterized<br />

our proposal as a “non-coverage determination” of remote<br />

critical care services and described an intensive care unit<br />

(ICU) model that integrates continuous surveillance of the<br />

ICU with an electronic medical records interface. <strong>This</strong><br />

model is also programmed to automatically prompt the<br />

physician to rapidly respond and intervene in the event of<br />

certain changes in a patient’s physiological status. Many<br />

of these commenters included <strong>document</strong>ation and references<br />

to studies that the adoption of this model reduced medical<br />

104

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