Proposed Medicare Rule Radically Changes Telehealth Reimbursement

Proposed rule adds new billing code to assess patients’ pre-recorded videos

A new proposed rule by the U.S. Centers for Medicare & Medicaid Services (CMS) has the potential to drastically change the way that patients receive care and interact with their providers. The proposed updates to the Medicare Physician Fee Schedule give providers the resources to use new technology to communicate with patients, assess their condition remotely, and support them through treatment.

Following are three proposals included in the rule that would change the way providers are compensated for caring for patients using telehealth tools. These new codes are separate from the existing telehealth CPT codes and the Remote Patient Monitoring codes.

Medicare would reimburse providers for assessing images and videos sent by patients asynchronously.

Asynchronous — or “store-and-forward” — technology in healthcare typically refers to processes by which patients enter data remotely, the data is stored, transferred, and then eventually reviewed by providers. Asynchronous technology makes it possible for care and treatment to take place at times that are convenient for both the patient and provider. Currently, only demonstration projects primarily in Alaska and Hawaii are allowed to bill for services delivered asynchronously.

The proposed rule would provide reimbursement for a the assessment of patient-submitted, pre-recorded videos or photos through proposed code GRAS1. There are certain limitations — for example, if a related office visit occurs close to the submission of video/photo data, reimbursement for both the office visit and video or image review would be bundled into a single payment.

Providers would be reimbursed for determining if patients need an in-person office visit.

To the extent that a provider uses a live audio or video call with a patient to determine whether an appointment is needed, providers will be able to be reimbursed for the interaction with the patient through proposed code GVCI1. In this case, CMS has limited the reimbursement to live interactions — also know as synchronous — in which the call is not related to a recent previous appointment, and no appointment subsequently occurs with that same provider. Essentially, Medicare will reimburse for the efficient use of communication technology that avoids unnecessary in-person appointments.

Providers could be compensated for using technology to support patients with opioid use disorder with medication assisted treatment (MAT).

Medicare acknowledges that technology could be used to help combat the opioid epidemic. The proposed rule asks for public comment on whether a bundled code specific to MAT would be helpful, and if so, what the components could be. CMS lists medication management, counseling, and observed dosing as common elements of MAT that might be delivered using communication technology.

CMS asked the public to provide comments by September 10, 2018 and the final rule would become effective starting January 1, 2019.