/"Under the proposal from CMS, covered products must haveFDA
clearance... Additionally, DMHT devices must be furnished "incident
to" a qualified practitioner's professional services via a prescription
or order in association with ongoing treatment under a plan of care –
and patients can use DMHT devices at home, in an office or in other
outpatient settings (if that is how the device has been cleared by the
FDA).... The codes encompass several key components: supply of the DMHT
device, the initial education and onboarding of the patient, the first
20 minutes of monthly treatment management services related to the
patient's therapeutic use of the device, and each subsequent 20 minutes
of monthly treatment management services."
/
_I see some serious upsides for us and clients:
_
Ability to do all of this, and get paid. I used to rent/sell FDA
approved devices for anxiety and sleep (CES Ultra), but clients had
to be able to afford them out-of-pocket.
It potentially lets us manage more clients by outsourcing some
treatment to devices.
It could let us turn shallow stuff over to devices (breathing
exercises) so we can concentrate on depth therapies in-session.
I see some serious downsides for us and clients:
It potentially lets us manage more clients by outsourcing some
treatment to devices. If large clinics and insurers run with this,
it will increase the caseloads of employee therapists and lower our
time per client.
It lets deep-pocketed device TechBro start-ups further push into the
mental health space.
It may encourage insurance companies to push devices before people.
Fewer authorized sessions?
This feels very similar to my personal unsubstantiated opinion that
therapists will shortly become the equivalent of "Tier 3 Tech
Support" -- I said there would be fewer of us, managing chatbots
under our licenses. But -- same idea -- there could be fewer of us,
managing "Tier 1" medical therapy devices.
It really depends upon how this is implemented and paid for. Done right
-- it gives us many more tools and pays for them. Done right, it lets
us do the deeper work in session. Done wrong, it devalues and removes
therapists from the equation. Why have a therapist work with anxiety
when the PCP can assign a nurse to watch over the medical devices and
capture the business for themselves?