The proposed rules for 2019 seek to add additional codes for telehealth services which were previously bundled into E/M. It also seeks to expand the type of services which may be considered telehealth services.
Currently, CMS restricts payment for telehealth service to those services which are enumerated in Section 1834(m)(4)(F)(i) of the Act and furnished in a setting defined in Section 1834(m)(4)(C).
The proposed rules seek to carve out certain types of services that are performed using communication technology, but not considered “telehealth.” Therefore, these services would not be subject to the limitations in Section 1834(m) and may be reimbursed under the Physician Fee Schedule. If adopted, the rules would allow physicians to be paid for these types of services furnished on or after January 1, 2019.
Currently, check in services that occur before or after an office visit are typically bundled into the office visit E/M code. CMS recognizes that payment disparities arise when non-face-to-face communication is disproportionately higher than other visits. Similarly, there are payment disparities when non-face-to-face communication does not result in an office visit which can be billed. CMS recognizes that check-ins can be more effective in addressing patient concerns, and can reduce the need for unnecessary office visits.
The proposed rule seeks to add a new code for these virtual check-ins. The new code would allow physicians to bill for non-face-to-face physician services furnished using technology, provided that: 1) the patient is established, and 2) the check-in is not related to an E/M service provided within the previous 7 days, or a procedure within the next 24 hours, or soonest available appointment. The new code would be a standalone service provided that it does not relate to an E/M service; otherwise, the service would be bundled into the previous E/M code. The new virtual check-in code would be reimbursed at a lower rate than existing E/M in-person visits.
Remote Patient Monitoring
Currently, payment for physician use of patient-recorded video and images, such as health rate monitors, to evaluate a patient’s condition is only paid under very limited circumstances. CMS seeks to create a code for remote professional evaluation of patient-transmitted information conducted via pre-recorded video or image technology. Similar to virtual check-ins, this service is not meant to be a substitute for an office visit; rather, it is meant to help determine whether an office visit is warranted. Unlike virtual check-in services, the proposed rule for remote evaluation of pre-recorded patient information is not restricted to existing patients. It is worth noting that remote evaluation of pre-recorded information uses still video or images, while virtual check-ins use real time transmission of any recorded image.
Additional Telehealth Services
CMS also seeks to review requests for additional services to be added to the enumerated list of telehealth services in Section 1834(m) of the Act. CMS will review requests for additional services to determine whether the service provides a clinical benefit to the patient. The additional services would be considered during the 2020 rule changes.
The proposed telehealth rules aim to improve patient’s access to health care, while mitigating the need for unnecessary (and costly) office visits.