The physician fee schedule has been released by Centers for Medicare & Medicaid Services (CMS) for 2019. The goal is to modernize the healthcare system and restore the relationship between physician and patient while decreasing the administrative burden. The changes include the Medicare Telehealth policy reimbursement and a new interpretation of the Telehealth reimbursement requirements. The services Telehealth delivers for Medicare are limited under the Social Security Act’s statue 1834(m) to specific patient locations, technology, providers and services. CMS is concerned this may limit the coding for new types of services used by communication technology.
CMS has expressed their belief they are obligated to restrict only services such as psychiatry office services, office visits and professional consultations. These services are paid the same way as an encounter between a health care professional and a physician. Additional remote services using communication technology are not classified as Medicare Telehealth services and are not restricted. This includes interactions between a patient and medical professional using remote communication technology. Reimbursement has been finalized by CMS for patient information remotely evaluated and pre-recorded, virtual check-ins and inter-professional internet consultations. CMS believes these services are not part of the Medicare Telehealth policy for services.
Brief Communication Technology services are used to evaluate the necessity of services and office visits under HCPCS code G2012. This only includes real-time, audio telephone interactions and two-way synchronous audio interactions with data transmission or video enhancements. CMS agrees to pay roughly fourteen dollars for this service. CMS believes the potential for unnecessary office visits will be mitigated by the check-ins.
Remote Evaluations under HCPCS code G2010 for pre-recorded patient information have been finalized by CMS with the creation of a new code describing professional evaluations in regards to professional remote evaluations of information transmitted by the patient using image or video technology. These services are not restricted by Medicare Telehealth.
Interprofessional Internet Consultation codes will include consultations performed using communications technology including internet and telephone. A team based approach is supported for care facilitated by technology for electronic medical records.
Codes for remote evaluations and virtual check-ins will only be provided to practitioners providing E/M services excluding clinical staff such as physical therapists and RN’s. Co-payments will still be applicable.
CMS has also changed services by adding geographical exemptions and originating sites for treating acute stroke and end stage renal disease. The list of services through Telehealth now includes the new codes G0513 and G0514 in relation to prolonged preventive services. The new remote physiologic monitoring codes are 99453, 99454, and 99457 and chronic care management code 99491. The rule details which policies will be applicable to FQHCs and RHCs and the corresponding PPS rates. RHC and FQHC are not eligible for billing using codes for interprofessional internet consultations.
The interim final rule implements changes according to the Support for Patients and Communities Act. Exemptions are provided for Telehealth’s requirements for SUD with a comment period. CMS will accept comments for separate bundled payments for treatment of SUD’s including elements of MAT and routine counseling based on the web. Bundled payments and comments for the interim final rule are accepted for sixty days from November 23rd.
An analysis and breakdown of the new elements are available on the CCHP infographic and factsheet including how the rule pertains specifically to RHCs and FQHCs.
CMS has released a proposal addressing required changes for the Medicare Telehealth policy regarding the 2018 Bipartisan Budget Act. The CMS proposal enables the provision of additional Telehealth benefits for MA plans. Additional Telehealth benefits must meet the following conditions.
All benefits provided by an MA plan must be available with Medicare Part B. They must not be payable under section 1834 (m) and be identified as applicable by the plan as appropriate for electronic exchange.
The MA plans will decide what services are clinically appropriate. Comments will be solicited by CMS regarding further limitations and eligibility of Part B services for Telehealth benefits.
The MA plans providing additional benefits through Telehealth must meet certain requirements. Additional Telehealth service benefits must be available as services for in-person. The provider directory must identify the Telehealth benefits offered by the providers.
The plans must comply with the credentialing requirements and provider selection located in 42 CFR § 422.204, provide written procedures and policies for the evaluation and selection of providers and follow a documented process for suppliers and providers. Upon the request of CMS, additional Telehealth benefits must be provided by the plans.
Contracted providers must be used to provide additional benefits from Telehealth. The additional benefits must have the same coverage requirements and access applicable to all basic benefits. State laws pertaining to the practice of medicine are applicable. MA plans in compliance with the requirements may include additional benefits from Telehealth regarding bidding for basic benefits. Any plan failing to meet these requirements must treat any benefit as supplemental.