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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
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