What is CMS proposing that is so concerning?
- CMS has decided that the technician's work (clinical activity code) needs to be changed from one that is 100% related to the physician's work to one that is not related at all to the physician's work.
According to QUARC, this has more wide-ranging implications because if the physician's work is not related to the actual treatment, then what is the physician supervising? Since 99183 will be up for review in 2024 (they want to break it up into 30-minute segments), the language in the G0277 code will need to parallel the language in the physician work description, which is a problem. Again, if the technician's work is unrelated to the physician's work, what work is the physician doing? HBO2 is not a static treatment; it is fluid, and adverse events can occur at any phase of the treatment. The lowest level of CHT is basic EMT, and only an advanced provider can intervene if there is a seizure, so how is it that the supervision of the treatment and monitoring of the patient by the CHT/RN is not related to the work of supervising the patient that is part of the physician's responsibility.
2. The monoplace hyperbaric chamber is only being used for 15 minutes out of the 30-minute segment.
This language demonstrates that CMS does not understand that when the patient is receiving a hyperbaric treatment, the hyperbaric equipment is used for the entire time.
3. The most common place for HBO2 to be given is in the monoplace environment. CMS has the >50% rule, where at least 50% of the patient encounters need to be given in the environment that is being used.
According to QUARC, based on the above 50% rule, CMS is not looking at the multiplace experience.
Research presented at the 2023 ASM, showed that even facilities with two monoplace
chambers, it was not typical for one technician to supervise eight (8) patients per day, assuming the 1:2 ratio of technicians to patients.
The researchers also noted there was no way to account for the additional staff utilized during patient transition or required to assist in the event of an emergency or fire, so a 1:1 technician-to-patient was the most common scenario.
4. CMS proposes refining the clinical labor time from 3 to 2 minutes.
The responsibilities of the technician for preparing the patient for hyperbaric treatment, discharging the patient post hyperbaric treatment, and preparing the hyperbaric chamber for the next treatment certainly take more than 2 minutes. CMS does not understand that hyperbaric patients are complex, often having as many as eight co-morbid conditions, which often require significant effort to get the patients treated in hyperbaric medicine. Additionally, post-COVID, cleaning procedures for hyperbaric equipment are more complicated.
QUARC believes that form letters will not adequately describe the nuances and workflow associated with the technician-patient clinical interaction prior to, during, and after the service is provided, and therefore, recommend providing comments in your own words.
COMMENTS NEED TO BE IN BY SEPTEMBER 11, 2023, by 5 PM EST.
Go to: https://www.regulations.gov/document/CMS-2023-0121-1282, click on the COMMENT tab, and refer to file code CMS-1784-P.
Select a comment category and enter your professional designation.
Attachments are allowed.
Thank you.
UHMS QUARC Committee Co-Chairs
Helen Gelly, MD
Caroline Fife, MD
