Safian & Co. Issues Public Comment on Centers for Medicare & Medicaid Services Proposed Rule

WASHINGTON, Sept. 29 -- Keith F. Safian, CEO advisor at Safian & Co. LLC, Armonk, New York, has issued a public comment on the Centers for Medicare and Medicaid Services proposed rule entitled "Medicare Program: CY 2021 Revisions to Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; etc.". The comment was written on Sept. 8, 2020, and posted on Sept. 23, 2020:

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1. Interactive communication is a challenge for many seniors:

a. No cellphone - can receive only landline calls - when they are awake and at home

b. Flip Phone - no video available

c. Computer but no camera and/or speakers - no video calls

d. Hard of hearing - often miss phone calls

2. The reimbursement offered for 20 minutes per month of interactive communication is inadequate.

a. Interactive communication is too time-consuming to establish multiple times each month for each patient.

i. Repeated attempts will be needed to finally connect with each patient

ii. Or, physicians will need to schedule these calls, an additional nonreimbursable burden on their office staff

b. The time investment for interactive communications, in addition to time spent reviewing monitoring data, is disproportionate to the modest reimbursement currently available for RPM, so providers cannot afford to offer it.

i. They will be incented to set up fully-reimbursable tele-health visits which generate more income, or

1. many more in-person visits, contrary to everyone's best interest given COVID-19.

3. It is a waste of provider AND patient time to connect with each patient repeatedly to achieve 20-minutes per month when results are normal and conditions are stable,

a. One significant value of RPM is that it permits a high level of ongoing surveillance without interrupting the patient

b. Providers need have interactive communication with patients only when there is a clinical reason to do so

i. Imagine a diabetic patient getting 20 calls per month from their provider - each call confirming that the patient's glucometer readings are normal

1. The patient says: why are you calling me again - I know that my glucometer reading was normal

ii. Then, when RPM identifies that this patient actually has a clinical problem, he/she is less likely to respond to the provider's call, since the previous 19 calls were only confirming normal results

1. This is analogous to "alert fatigue" - the patients might not respond when there is an actual problem -like the boy who cried wolf

4. RPM does not interrupt the patient unnecessarily.

a. The IFR completely removes that advantage

b. If they receive too many calls, many patients will discontinue RPM, resulting in increased avoidable E.R. visits and hospitalizations

5. The IFR changes will make RPM less available:

a. RPM now permits Hospital discharge planners to send a patient home to their residence even when they live alone, knowing that RPM will be continuously monitoring their activities of daily living and physiologic measures.

i. They know that if the patient's activity levels or measures change, RPM will trigger early interventions.

b. If RPM is less available because of the proposed changes:

i. Many patients, who would have returned to home with RPM, will instead be placed in assisted living, short-term rehab, or nursing homes, at substantially increased cost.

ii. Early detection of deterioration will no longer be available, resulting in increased E.R. visits and hospitalizations

6. Summary: the new interactive communication requirement will:

a. Discourage patients from using RPM

b. Stop providers from offering RPM

c. Increase admissions to long-term care facilities

d. Deny patients the ability to age-in-place with dignity

e. Increase avoidable E.R. visits and hospitalizations

f. Increase reimbursable in-person provider visits

7. Conclusion: the IFR interactive communication requirement will drive up healthcare costs and result in increased morbidity.

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Keith F. Safian's Profile:

* 25 years as a hospital CEO of a suburban community hospital

* 15 years as a hospital administrator at Kings County Hospital, NYU Medical Center, and a community teaching hospital

* CEO Advisor to three telemedicine and RPM businesses, and numerous physician practices

* Wharton MBA; Bachelor's Degrees in Industrial and Electrical Engineering

Keith F. Safian's Contact Information

Keith F. Safian, MBA, LFACHE

CEO Advisor / Healthcare CEO

Safian & Company, LLC

18 Cole Drive, Third Floor

Armonk, New York 10504-3011

Telephone: 914 273-7375

Cellphone: 914 282-7011

ksafian@safian.us

http://safian.us

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The proposed rule can be viewed at: https://www.regulations.gov/document?D=CMS-2020-0088-1604

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