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CMS-1403-FC
Response: We are pleased that the majority of
commenters supported our proposal to create a new series of
HCPCS codes for follow-up inpatient telehealth
consultations. As discussed in the CY 2009 PFS proposed
rule, we considered other approaches to provide and bill
for follow-up inpatient consultations delivered via
telehealth. In response to the comments requesting that we
approve subsequent hospital care for telehealth only when
the codes are used for follow-up inpatient consultations,
we were concerned that the other approaches under
consideration would lead to a misuse of the service, and
practitioners would provide a broader range of services via
telehealth than was formerly approved, including the
ongoing, day-to-day E/M of a hospital inpatient. We were
also concerned that it could be difficult to implement
sufficient controls and monitoring to ensure that whatever
mechanism we created would be limited to the delivery of
services that were formerly described as follow-up
inpatient consultations. We continue to believe that
creating HCPCS codes specific to the telehealth delivery of
follow-up inpatient consultations allows us to provide
payment for these services, as well as enables us to best
monitor whether the codes are used appropriately.
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