Davis Vision Position Statement - Digital Optometrics

Davis Vision Position Statement

A Position Statement on Telehealth Services February 24, 2018

Davis Vision/Superior Vision support telehealth services to improve access and quality of care
while reducing costs.


Healthcare reform in America remains at the forefront of national discussion. As medical costs
continue to rise, employers and insurers must share more costs with employees/patients. As a
result, American citizens are more engaged than ever before in the debate about how and where they
receive medical services. The healthcare industry, like many others, is realizing a paradigm shift
from being provider- controlled to consumer-driven, which, demands that the delivery system adopt a
more consumer focused approach. Furthermore, due to an increase in the aging population, the number
of U.S residents with impaired vision could more than double over the next three decades1 (Prevent
Blindness America, 2013). This will only serve to compound the need for greater access to initial
vision screenings and real-time patient-provider communication.


The Federal Health Resources Service Administration (HRSA) defines Telemedicine as “…the use of
electronic information and telecommunications technologies to support and promote long distance
clinical healthcare, patient and professional health related education, public health and health
administration.” The term “Telehealth” is commonly used interchangeably with “telemedicine2”.

Davis Vision/Superior Vision embrace the opportunities for telemedicine to improve access, lower
costs and improve the quality of care. We also recognize the responsibility of managed care
organizations, professional societies and government agencies to serve the best interests of
patients by strictly overseeing matters of safety, privacy, security and professional practices.

Policy Considerations

The advances in telemedicine and related technologies3 are supported by the rapid rise in
utilization and acceptance by both providers and consumers4. Studies5 indicate outcomes
utilizing telemedicine technologies alone, or in coordination with “usual care” were similar or
better than outcomes with “usual care” alone.

The standards of CMS/Medicare, The Health Resources Service Administration (HRSA), The Food and
Drug Administration (FDA), The National Conference of State Legislatures, the Federation of State
Medical Boards and The National Academies of Science, Engineering and Medicine were utilized in
developing Davis Vision | Superior Vision criteria for reimbursable telemedicine services. They are

1. The technology must support the doctor patient relationship as that is understood in
traditional medical practice.

2. The technology must authenticate the location and identity of the requesting patient.

3. The technology must disclose and validate the identity and appropriate training of the
professional rendering care.

4. Appropriate informed consent must be obtained referencing the advantages, limitations and
alternatives of these technologies.

5. The patient must have access to the record documenting the care received

6. The professional providing care must be appropriately licensed and the telemedicine services
must be approved by both the jurisdiction extending the professional license and the jurisdiction
in which the patient is resident.

7. The licensed professional providing telemedicine services is responsible for the supervision
of any non-physicians involved in patient care.

8. The physician must have liability insurance specifically referencing telemedicine services.

9. The standard of care for telemedicine services shall be the same as traditional medical care.

10. The telemedicine service organization and professional must have policies and procedures
assessing patient satisfaction, safety, privacy and security of the medical record consistent with
federal and state regulations

11. The technology must be validated by publication in the peer reviewed literature

Coverage Considerations

Davis Vision | Superior Vision will follow the telemedicine reimbursement policies of CMS/Medicare
as they apply to covered beneficiaries. Current Procedures and Terminology 4 of the American
Medical Association (CPT 4) recognizes the modifiers -GQ and -GT as descriptors of telemedicine
services. The modifier-GQ references asynchronous store and forward technologies such as those used
in screening for diabetic retinopathy. The modifier -GT describes services offered “via interactive
audio and video telecommunications system” that are real time direct doctor patient interactions
with standards of security and privacy consistent with federal and state regulations. Under
current CMS/Medicare regulations the – GT modifier may only be used for eligible “Originating”
sites. CMS Medicare has specific codes that are eligible for use with the -GT modifier. Any code
not specifically approved by CMS Medicare will not be approved.

Davis Vision/ Superior Vision will follow telemedicine reimbursement policies for state
jurisdictions where we do business. These relate to Medicaid and commercial populations. Except as
noted by federal waivers, reimbursement policies for dual eligible members will be governed by
federal policy.

Mark C. Ruchman MD Chief Medical Officer


1. Prevent Blindness America (2013). Vision Problems in the U.S. Retrieved from
https://www.preventblindness.org/sites/default/files /national/documents/state-fact-

2. “Telehealth.” HRSA Rural Health Glossary. Accessed November 17, 2014.

3. There are now 237.6 million smart phones in the United States-Statistica/Google Search

4. 52% of over 100 million patient encounters at Kaiser Permanente now occur remotely- Paul Lee
MD,JD at FDA Workshop on Digital Eye Care October 23,2017

5. Telemedicine Impact on Health Care Cost and Quality (2015), The American Telemedicine
Association. A review of 93 randomized clinical trials utilizing telemedicine technologies


175 East Houston Street San Antonio, TX 78247

Davisvision.com | 1 (800) 999-5431


939 Elkridge Landing Road, Suite 200

Linthicum, MD 21090

Superiorvision.com | 1 (800) 243-1401