PFS Comment - Integral To

Digital Mental Health Treatment Devices (DMHT Devices)

First, I support the proposed Medicare policy for DMHT.  

Second, these may be difficult to price as an average price.  Just as Part B drugs have two payment parts - such as a CPT code for infusion and a HCPCS code for the drug - the "average price" or "typical price" RUC/CMS methodology may be difficult here.

Third, CMS should acknowledge this is a step forward in policy to refer to items as "incident to or integral to" - we have long paid for items that are incident to or integral to.  In fact, the payment concept was formerly "incident to."  Even in this proposed rule, one section refers to "incident to or integral to" while another requires the service to be "incident to."   Historically, numerous items considered "integral to" a physician service were not payable because they were not "incident to."  Witness the line item of statute that makes take-home allergen injections a benefit category. This would have been unnecessary if they were payable as "integral to" like take-home software now is.   While I support the expansion of policy from "incident to" to "integral to," CMS may find it is harder to define the outer borders of "integral to" relative to the definition of "incident to" (e.g. a cancer drug administered while the physician is somewhere in the office suite is "incident to.")

Comment Tracking Number: m06-03ix-0u0w