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CAH impact: CMS telemedicine survey letter

Medicare Update for CAHs, September 7, 2011

CMS has issued a survey and certification letter regarding telemedicine services in hospitals and critical access hospitals (CAH). Effective July 5, 2011, permit hospitals and CAHs are permitted to provide telemedicine services to their patients through written agreements with a distant-site hospital or a distant-site telemedicine entity, according to the CMS letter.

Telemedicine, as the term is used by CMS, means “the provision of clinical services to patients by physicians and practitioners from a distance via electronic communications.” The distant-site telemedicine physician or practitioner provides clinical services to the hospital or CAH patient either simultaneously (as in teleICU services), or non-simultaneously (as is the case with many teleradiology services), according to CMS.

The updated CMS guidance states that these services must be provided under a written agreement between the hospital or CAH, and one or more:

  • Distant-site hospitals that participate in Medicare; or
  • Distant-site telemedicine entities. For the purposes of this rule, a distant-site telemedicine entity is defined as an entity that (1) provides telemedicine services; (2) is not a Medicare-participating hospital; and (3) provides contracted services in a manner that enables a hospital or CAH using its services to meet all applicable Conditions of Participation (CoPs), particularly those requirements related to the credentialing and privileging of practitioners providing telemedicine services to the patients of the hospital or CAH.

“CAHs have unique staffing issues for both employees and physicians. It is not uncommon for a CAH to contract out certain telemedicine services “after hours,” says Debbie Mackaman, RHIA, CHCO, regulatory specialist for HCPro, Inc. This change allows more flexibility for CAHs who contract with those services who are not considered to be Medicare-participating hospitals but the CAH still meets the CoPs overall.”

She continues, “In addition, it decreases the paperwork burden on CAHs by requiring the telemedicine distant site to conduct the privileging and ensure that the physician holds a license to operate in the same state as the CAH.”  

There are a number of other requirements concerning the written agreement between the CAH or hospital, which include requirements that:

  • The distant-site hospital or telemedicine entity must provide a list of telemedicine physicians and practitioners who are privileged there;  and
  • The hospital or CAH must review the services provided to its patients by telemedicine physicians and practitioners covered by the agreement. The hospital or CAH must also provide written feedback to the distant-site hospital or telemedicine entity, addressing, at a minimum, all adverse events or complaints related to the telemedicine services provided at the hospital or CAH.

“CAHs that have hesitated contracting telemedicine services in the past due to the past restrictions may want to reconsider this valuable service as an alternative to certain hard-to-recruit medical staff positions,” says Mackaman.

View the CMS letter here:

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