CMS Proposes Expansion of Telehealth Services

The Centers for Medicare and Medicaid Services (CMS) recently issued a proposed rule that revises the Medicare Physician Fee Schedule and other Medicare payment policies for telehealth services.

Over the past decade, stakeholders in the health care industry have voiced their support for telehealth services, explaining how modern communication technology can promote care coordination, ensure patient compliance with treatment plans and improve overall quality of care. Adhering to the trend, many states passed laws to promote telehealth services and continuously revised such laws to account for changes in technology and patient demand. On the federal platform, however, CMS was criticized for failing to revise its regulations, which impose strict barriers to the provision of telehealth services under the Medicare program.

CMS now seeks to promote access to telehealth services by proposing  reimbursement for the following services provided via communication technology:

1.     Virtual Check-in (HCPCS Code GVCII)

Traditionally, reimbursement for remote patient communication that occurs before or after an in-patient visit is bundled into the payment received for the in-person visit itself. If a communication does not result in an in-person visit, then the physician, or other qualified health professional, will not be reimbursed for such communication. Under the CMS proposed rule, Medicare would create a separate code to reimburse providers for “check-in services,” which would apply when a physician or other qualified health professional uses communication technology to check-in with a patient and determine whether an in-person visit is warranted based on the patient’s symptoms or complaints. To the extent a check-in service would lead to an in-person visit, however, the check-in service would not be billed separately and instead would continue to be reimbursed as a bundled payment with the in-person visit.

CMS explains that such check-in services can reduce unnecessary office visits, thereby reducing overall cost of care. The proposed rule does not, however, explain the type of communication technology that can be used for such services. CMS is requesting comments from the public on the type of communication technology commonly used by providers and, specifically, whether standard telephone conversations would be adequate to assess a patient’s condition, as compared to enhanced video or other types of communication.

2.    Remote Evaluation of Pre-Recorded Patient Information (HCPCS Code GRAS1)

The proposed rule also establishes separate reimbursement when providers review pre-recorded videos and/or images recorded by a patient to assess the patient conditions and determine whether an in-person visit is necessary. Consistent with the proposed reimbursement rule for check-in services, such remote evaluation services would only be reimbursed separately  if they do not result in a follow-up in-person visit.

A key detail in the proposed reimbursement for remote evaluation services is that it does not require the provider to engage in real-time interactions with the patient, as is traditionally required for currently reimbursable medical health services. Rather, the proposed rule would permit the services to be provided via “store-and-forward” communication technology that provides for asynchronous transmission of patient information.

3.    Interprofessional Internet Consultation (CPT Codes 994X6, 994X0)

CMS has recognized that a team-based approach to care can reduce costs and improve patient outcomes. Accordingly, it has proposed to also unbundle and permit separate billing for consultation services conducted through telephone, internet or other communication technology. Such services are commonly provided when a provider seeks the opinion or treatment advice of another qualified health care professional with specific expertise to assist in the diagnosis and/or management of a patient’s condition. CMS explains that such consultation services may often be provided without the need for an in-person interaction between the consulting provider and the patient, in which case it warrants allowing the provider to bill for such services independently.

4.    Other Proposed Revisions to Medicare Telehealth Reimbursement

In addition to the new reimbursement rules described above, CMS is also proposing the following changes to the Medicare telehealth regulations:

• Adding prolonged preventive services (HCPCS Codes G0513, G0514) to the list of Medicare telehealth services that can be provided via communication technology;
• Adding renal dialysis facilities and the homes of patients suffering from end-stage renal disease (ESRD) as locations that qualify as “originating sites” where a patient can be located when receiving monthly ESRD-related clinical assessment via telehealth; and
• Adding mobile stroke units (i.e., mobile units that diagnose, evaluate and/or treat symptoms of an acute stroke) as permissible “originating sites” for the provision of acute stroke services via telehealth.

CMS is accepting public comments on the proposed rule until September 10, 2018. If the rule is passed, the new telehealth reimbursement rules would go into effect on January 1, 2019.