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CMS-1403-FC
As discussed in the CY 2009 PFS proposed rule
(73 FR 38516), §414.65 provides for the payment of
individual MNT furnished via telehealth. Group MNT is not
an approved telehealth service, so it cannot be used as a
point of comparison for group DSMT (as represented by HCPCS
code G0109). In addition, group counseling services have a
different interactive dynamic between the physician or
practitioner at the distant site and beneficiary at the
originating site as compared to services on the current
list of Medicare telehealth services. (See 70 FR 45787 and
70 FR 70157 for a previous discussion of group services.)
Since the interactive dynamic of group DSMT is not similar
to individual MNT or any other service currently approved
for telehealth, we believe that group DSMT must be
evaluated as a category 2 service.
Section 1861(qq) of the Act provides that DSMT (which
can be either a group or individual service) involves
educational and training services to ensure therapy
compliance or to provide necessary skills and knowledge to
participate in managing the condition, including the skills
necessary for the self administration of injectable drugs.
We believe individual DSMT is not analogous to individual
MNT because of the element of skill based training that is
encompassed within individual DSMT, but is not an aspect of
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