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TIA Submits Recommendations for Centers for Medicare & Medicaid Services' Proposed Medicare Payment Policy Revisions

Arlington, Va. (Sept. 2, 2014) – The Telecommunications Industry Association (TIA), the leading association representing the manufacturers and suppliers of high-tech communications networks, today submitted comments to the Department of Health and Human Service's Centers for Medicare & Medicaid Services (CMS) on proposed Medicare program revisions to payment policies under the Physician Fee Schedule, Clinical Laboratory Fee Schedule, and other revisions to Part B for CY 2015.

In its proposal, CMS has included proposals addressing the reimbursement for non-face-to-face complex chronic care management (CCM) that reflect the widely-held view that enhanced telemedicine and other related applications, including the remote monitoring of PGHD (patient biometric and physiological data) that have demonstrated better quality healthcare for patients, better access to medical specialists, and lower healthcare costs.

Commending CMS' action in this space, TIA specifically urged for CMS to:

  • Plainly communicate standards for the mandatory use of electronic health information technology in providing CCM;
  • Ensure that its CCM eligibility requirements are based on objective criteria;
  • Assign to CCM a Practice Expense Relative Value Unit of 0.93 and a Malpractice Expense Relative Value Unit of 0.09. In the alternative, CMS should clarify that CCM furnished by a Rural Health Clinic or Federally Qualified Health Center constitutes a Non-Rural Health Clinic or Non-Federally Qualified Health Center Service for which the Rural Health Clinic or Federally Qualified Health Center may bill separately. CMS should also permit CCM and Transitional Care Management furnished By a Rural Health Center or Federally Qualified Health Center to be furnished "incident to" under General Supervision;
  • Provide a model agreement for beneficiaries to consent to the provision of CCM;
  • Create an additional separate code for CCM incorporating electronic remote patient monitoring to which a higher Practice Expense RVU Is assigned; and
  • Account for remote patient monitoring in the new proposed Healthcare Common Procedure Coding System Code.

To access TIA's comments, visit this link.

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About TIA

The Telecommunications Industry Association (TIA) represents manufacturers and suppliers of global communications networks through standards development, policy and advocacy, business opportunities, market intelligence, and events and networking. TIA enhances the business environment for broadband, mobile wireless, information technology, networks, cable, satellite and unified communications. Members' products and services empower communications in every industry and market, including healthcare, education, security, public safety, transportation, government, the military, the environment, and entertainment. Visit for more details.

TIA is accredited by the American National Standards Institute (ANSI), and is a proud sponsor of ANSI’s Standards Boost Business campaign. Visit  for details.