TIA Blog

Recently, the Department of Health and Human Service's Centers for Medicare & Medicaid Services (CMS) requested input on proposed Medicare program revisions to payment policies under the Physician Fee Schedule, Clinical Laboratory Fee Schedule, and other revisions to Part B for calendar year 2015.

Despite its intimidating title, this rulemaking is extremely important. It puts forward proposed updates to relative value units (RVUs) – the dollar rates of reimbursement codes for various eligible activities by licensed clinicians – for 2015, and other Medicare payment policies, to ensure that its payment systems are updated to reflect changes in medical practice and the relative value of services.

These RVUs cover more than 7,000 services meant to account for the amount of work, malpractice expenses, and direct and indirect practice expenses associated with providing Medicare service, totaling approximately $513 million for 2014!

Because many TIA member companies develop, manufacture, and supply health information technologies and medical devices, producing the tools that allow patients and healthcare providers to connect virtually anytime, TIA members are long-time supporters of enhanced telehealth services and remote patient monitoring solutions. These services and solutions are an essential part of modern medical care, but will not be taken up by licensed clinicians if there are no incentives to do so!

This is why, on September 2, 2014, TIA submitted extensive comments on CMS' proposals (available here). TIA was also proud to join a number of other stakeholders from across the healthcare space in a joint comment reflecting wide consensus on a number of important points (available here).

Non-Face-to-Face Services

While due to its magnitude, there is a natural impact in each year's proposed PFS, the proposed schedule for calendar year 2015 is particularly important because CMS has proposed a new approach to chronic care management (CCM). The approach to CCM includes "non-face-to-face" services which, as TIA encouraged CMS in 2013, should include enhanced telemedicine and other related applications, including the remote monitoring of patient-generated health data (patient biometric and physiological data) that have demonstrated better quality healthcare for patients, better access to medical specialists, and lower healthcare costs.

Please review our comments themselves, but in summary, TIA urges CMS to:

• Plainly communicate standards for the mandatory use of electronic health information CCM.
• Ensure that its CCM eligibility requirements are based on objective criteria.
• Assign RVUs that accurately reflect the breadth of services associated with CCM services.
• Provide a model agreement for beneficiaries to consent to the provision of CCM.
• Account for remote patient monitoring in the new proposed Healthcare Common Procedure Coding System Code.

TIA looks forward to further work with CMS and stakeholders across the healthcare space as we work together to ensure that each American receives the most effective and efficient care. And we are interested in your views!