Last year, the Centers for Medicare & Medicaid Services ("CMS") received public comments on a proposed rule to revise the requirements that long-term care facilities must meet to participate in the Medicare and Medicaid programs. Among other matters, the proposed rule purports to require physicians or designated professionals to evaluate nursing home patients in-person before transfer to a hospital. The American Telemedicine Association submitted a comment urging CMS not to restrict such pre-transfer evaluations to "in-person" context or alternatively to recognize other ways to achieve the intended purpose.
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