Feb 25, 2015 - As you continue to highlight ways the healthcare system of the 21st ... approach to telehealth and remote
February 25, 2015 The Honorable Frank Pallone The Honorable Fred Upton U.S. House of Representatives U.S. House of Representatives Washington, DC 20515 Washington, DC 20515 The Honorable Peter Welch The Honorable Gregg Harper U.S. House of Representatives U.S. House of Representatives Washington, DC 20515 Washington, DC 20515 The Honorable Bill Johnson The Honorable Greg Walden U.S. House of Representatives U.S. House of Representatives Washington, DC 20515 Washington, DC 20515 The Honorable Doris Matsui The Honorable Bob Latta U.S. House of Representatives U.S. House of Representatives Washington, DC 20515 Washington, DC 20515 Dear Representatives Upton, Pallone, Harper, Welch, Johnson, Walden, Latta, and Matsui: The undersigned organizations appreciate your work in the 21st Century Cures initiative, and to provide consensus views across a wide array of stakeholders. We encourage you to help millions of American Medicare beneficiaries realize the benefits of information and communications technology (ICT) in the care they receive. As you continue to highlight ways the healthcare system of the 21st Century can harness advances in medical science and technology, we agree that recognizing and implementing
policies for new and emerging telehealth and remote patient monitoring technologies and their adoption, must be a priority. Specifically, we write to urge you to ensure that Medicare appropriately supports the use of evidence‐based telehealth and remote patient monitoring services. Currently, Medicare does not comport with the concept of 21st Century eCare services which integrate innovative, systems‐enhancing and team‐based approaches. We believe that reform of Medicare’s approach to telehealth and remote patient monitoring (RPM) service coverage is urgently needed. RPM technologies (which are not telehealth services under Medicare’s definition of telehealth services) reduce inpatient care, readmissions, as well as improve care coordination. We note that CMS has already taken the position that services commonly furnished remotely using telecommunications technology (“electronically, rather than by means of a verbal description”) are paid under the same conditions as if the service were provided in‐person, providing a vital interpretation that ensures the proper reimbursement for the monitoring of PGHD. We believe there remains a need for Federal priorities to address the full potential of the health ICT ecosystem which is comprised of many technologies, including telehealth and RPM through full coverage in Medicare. As evidence of cost savings we would like to highlight the following examples of the impact of remote patient monitoring. Remote patient monitoring has the potential to positively engage patients when addressing chronic and persistent disease states to improve management of chronic conditions.1 The Hackensack Alliance in New Jersey reduced readmission rates from 28% to 5% for congestive heart failure patients.2 Christus Health reduced the average cost for congestive heart failure readmissions from $12,937 compared to $1,231 per re‐admission after implementing a remote patient monitoring system.3 CMS has stated that, because the challenges of preventing and managing chronic disease have caused “the focus of primary care [to evolve] from an episodic treatment‐based orientation to a focus on comprehensive patient‐centered care management,” the reimbursement for chronic care management that had historically been included in E/M codes was insufficient; instead, CMS concluded that chronic care management should be separately reimbursed. Furthermore, CMS has noted its anticipation that increased reimbursement for CCM will be more than offset by the corresponding reduction in more costly services. We believe that for these same reasons, CMS should separately reimburse – i.e., “unbundle” – RPM. We understand the need for legislation under the 21st Century Cures initiative to be budget‐neutral, and after consultations among stakeholders across the healthcare ecosystem, we offer detailed suggestions for a path forward. First, we strongly urge you to include language that permits all alternative payment models to cover effective telehealth and RPM services. Second, we recommend the following approach to covering RPM: Congress should establish an RPM benefit for beneficiaries with chronic conditions (Chronic Obstructive Pulmonary Disease [COPD], chronic hypertension, Congestive Heart Failure [CHF], diabetes, chronic kidney disease [CKD], etc.) and two hospitalizations in the prior 18 months. Congress should also require 1
Agboola, Stephen, et al. "Home blood pressure monitoring program improves management of hypertension." Circulation: Cardiovascular Quality and Outcomes 5.3 Supplement (2012): A118. 2
Use Case Study: Hackensack Alliance ACO ‐ Remote Patient Monitoring for Chronic Disease. HIMSS. 2014
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Use Case Study: Christus Health –Remote Patient Monitoring and Chronic Disease. HIMSS 2014.
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CMS to permit billing for the RPM Current Procedural Terminology (CPT) code 99091 one time per month, in addition to chronic care management (CCM) for beneficiaries with two hospitalizations in the last 18 months and a diagnosis of heart failure, COPD, CKD, chronic hypertension, diabetes and other chronic conditions. In order to advance budget‐neutral coverage for effective RPM, the patient features mentioned above should be coupled with the following: Congress should require CMS to implement this change within twelve (12) months of enactment, and to provide coverage for five (5) years. To assure budget neutrality, CMS should be directed to ensure that the patient’s qualifying criteria noted above are coupled with an evaluation of five (5) years of RPM coverage, where if it is determined that the benefit is not demonstrably resulting in savings or is not budget neutral, the benefit would end; Alternatively, if the patient limitations coupled with the evaluation/benefit curtailment that is detailed above does not prove to be effective, the undersigned would propose that Congress should: Require RPM coverage that would terminate at 12 months if the provider does not achieve savings in total care costs (physician services, outpatient services and hospital services) compared to the average total health costs for a beneficiary with the same risk adjusted disease (i.e., a provider would be barred from billing for RPM if he or she does not achieve the savings target). The amount of savings required to continue billing for RPM would be, from date of implementation: 1% in year one, 3% in year 3, and 5% in year five. *** We commend you for your leadership in taking a crucial, bipartisan approach towards modernizing the American healthcare system. Thank you and we look forward to working with you to enact these important reforms under the 21st Century Cures Initiative. Respectfully submitted, ACT | The App Association Alliance for Connected Care American Telemedicine Association Baxter Corporation Biocom Christus Health HIMSS Intel Panasonic Corporation of North America Personal Connected Health Alliance Qualcomm Telecommunications Industry Association Underwriters Laboratories
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