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CMS-1403-FC
way a “non-coverage determination” for remote critical care
services described by the AMA’s Category III tracking
codes, 0188T-0189T. Consistent with the AMA’s creation of
those tracking codes, we believe that remote critical care
services are different from the telehealth delivery of
critical care services (as defined by CPT codes 99291
through 99292). Category III CPT codes track utilization
of a service, facilitating data collection on, and
assessment of new services and procedures. We believe that
the data collected for these tracking codes will help
provide useful information on how to best categorize and
value remote critical care services in the future.
However, at the present time, we do not have sufficient
evidence that the provision of critical care services (as
represented by HCPCS codes 99291 and 99292) via telehealth
is an adequate substitute for an in person (face-to-face)
encounter.
c. Subsequent hospital care
Prior to 2006, follow-up inpatient consultations (as
described by CPT codes 99261 through 99263) were approved
for telehealth. CPT 2006 deleted the follow-up inpatient
consultation codes and advised practitioners instead to
bill for these services using the codes for subsequent
hospital care (as described by CPT codes 99231 through
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