Notice: This CMS-approved document has been submitted - Philips ...

CMS-1403-FC
Group DSMT (which comprises the vast majority of DSMT;
initial and follow up) is by definition furnished in a group
setting and, therefore, the interactive dynamic is not
similar to any existing telehealth service. No group
services are approved for telehealth. For more information
on our review of the use of telehealth to furnish group
services, see the CY 2006 PFS proposed rule (70 FR 45787).
In order to consider addition of services for Medicare
telehealth that are not similar to the existing list of
telehealth services, we require comparative studies showing
that the use of an interactive audio and video
telecommunications system is an adequate substitute for the
in person (face-to-face) delivery of the requested service.
To date, requestors have not submitted sufficient
comparative analyses supporting the approval of skill based
training (such as teaching a patient how to administer
self-injectable drugs) for telehealth. Likewise, requestors
have not submitted comparative analyses showing that the use
of a telecommunications system is an adequate substitute for
group counseling services (DSMT or otherwise) furnished in
person.
We agree with the commenters that skill-based training,
such as teaching patients how to inject insulin, would be
difficult to accomplish without the physical in person
presence of the teaching practitioner. However, we disagree
that this training element should be carved out of
individual (or group) DSMT for purposes of providing
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