Via Christi Health System is the largest provider of healthcare services in Kansas, with underserved in rural and urban populations. VCHS invested 14 million dollars in eICU technology. Lack of reimbursement for TeleICU services is barrier to provision of these services.
VCHS appointed a task force charged with reviewing current state and federal policy regarding telemedicine technology. The first addressed the lack of a uniform approach by Kansas legislature. Working through the Kansas Department of Insurance, VCHS joined with other providers in requesting the state to appoint a task force to study telemedicine coverage policies.
Kansas HB 2065 and HB 6331 force launched an all-out lobbying campaign to mobilize staff in a series of Action Alerts generating numerous calls and emails to our congressional delegation. VCHS then responded to CMS for reimbursement under Medicare Part B .The comment was 73 Fed. Reg. 130, July 7, 2008, pursuant to instructions posted in the Proposed Rule (CMS –1403 –P). In Part II D of the proposed rule, CMS states that critical care is a Category 2 service not similar to any current Medicare telehealth services. Our position stated “can be an adequate substitute for a face-to-face encounter. The VCHS comment was provided to CMS with details of VCHS's view of telehealth critical services and two recommendations.
Recommendation 1 –VCHS recommends CMS determine telehealth critical care services to be an adequate substitute to bedside physician care provided to critically patients and thereby make telehealth critical care a Category 1 Service, eligible to be reimbursed under CPT codes 99291 and 99292. Recommendation 2 –VCHS also recommends CMS consider creating modifiers that may attach to CPT codes 99291 and 99292 to indicate the critical care services are provided as telehealth critical care services.
Further collaboration lead to a formal response to a proposed CMS rule regarding reimbursement under Medicare Part B for critical care services provided via telecommunications for critically ill stroke patients.
Elizabethann Cowboy, No Financial Disclosure Information; No Product/Research Disclosure Information