Will My Doctor Be a “BOT?”

Will My Doctor Be a “BOT?”

There appear to be a number of possibilities where a BOT could be used to provide a service.

I admit it, I am a nerd and I have done a lot of programming during my career,  but can software be a service separately payable by Medicare and other payers?  Medicare may be saying yes.  Software developers have been pushing artificial intelligence (AI)- driven systems to help practitioners make clinical decisions. 

While not going all the way, the Centers for Medicare & Medicaid Services (CMS) is finalizing an exception to their general packaging policy for “Software as a Service” or “SaaS” add-on codes. The SaaS add-on codes will be assigned to identical APCs and have the same status indicator assignments as their standalone codes, thereby allowing for separate payment for these services. CMS is also continuing to consider for future rulemaking relative to how payment policies should adapt in order to better recognize these evolving services.

Let’s cut to the chase.  SaaS advocates want providers to be able to bill for interactions that patients have with computer software.  Physicians and other providers see a financial wind fall if they can bill when software is used to reach a diagnosis of a condition.  

As AI evolves, I can see it is inevitable that certain medical services will be replaced by software driven services.

This is increasingly impacted by the evolution of devices like smart phones and similar devices. 

Here are some examples where a “BOT” could be used to provide a service:

  • A diabetic patient, uploads blood sugar readings from their smart phone, to get a new prescription for their diabetic medication.
  • A patient uploads an EKG reading from their cell phone to see if they have a heart condition requiring additional treatment.
  • A patient with COPD uploads the reading from a medical device to get a modification to their prescription.

There is huge potential for AI in healthcare, but I hope we can avoid the abuse that could occur as SaaS becomes widespread. 

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Timothy Powell, CPA, CHCP

Timothy Powell is a nationally recognized expert on regulatory matters, including the False Claims Act, Zone Program Integrity Contractor (ZPIC) audits, and U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) compliance. He is a member of the RACmonitor editorial board and a national correspondent for Monitor Mondays.

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