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

follow-up inpatient consultations in a face-to-face<br />

encounter must continue to utilize subsequent hospital care<br />

codes (as described by CPT codes 99231 through 99233), we<br />

believe it is appropriate to set the RVUs for the new<br />

telehealth G codes at the same level as for the subsequent<br />

hospital care codes.<br />

Comment: Several commenters enthusiastically<br />

supported our proposal to create a new series of HCPCS<br />

codes for follow-up inpatient telehealth consultations.<br />

Some commenters were concerned that our proposed definition<br />

of the new HCPCS codes did not clearly distinguish these<br />

consultations from subsequent hospital care, and they<br />

believed it would not preclude the use of telehealth for<br />

the ongoing E/M of an inpatient. Other commenters<br />

supported our effort to reinstitute follow-up inpatient<br />

consultations delivered via telehealth, but discouraged us<br />

from creating new HCPCS codes for the long-term. A few<br />

commenters recommended that instead we approve subsequent<br />

hospital care for telehealth. The AMA and others urged us<br />

to implement the proposed G codes as an interim measure,<br />

while working expeditiously with the CPT Editorial Panel<br />

and the RUC to develop appropriate codes and RVUs for the<br />

long-term.<br />

109

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