On July 12, 2018, CMS included three proposed changes to telehealth reimbursements within the CY 2019 Physician Fee Schedule (the “Proposed Rule”). Currently, subject to certain exceptions, Medicare reimbursements for certain telehealth services are statutorily limited by the type of health care professional providing the service, and the geographic location of the patient (namely, the patient must be located within a “Health Professional Shortage Area” for a provider to seek reimbursement for certain telehealth services). In the Proposed Rule, CMS clarifies that such statutory restrictions do not apply to all services provided via remote communication technology; rather such restrictions apply only to a distinct set of services that are ordinarily reimbursed as if they were furnished in person. With this distinction in mind, CMS has proposed three new telehealth scenarios for provider reimbursement that would not be limited by the statutory restrictions:
- Brief Communications Technology Based Services (Virtual Check-Ins). CMS has proposed payment to providers for brief non-face-to-face check-ins with an established patient via real time communication technology for the purposes of assessing whether an in-person office visit is necessary. Importantly, reimbursement for a virtual check-in would not be available if the virtual check-in occurred after an in-person office visit within the previous 7 days, or if it leads to an in-person office visit within 24 hours (or at the earliest available appointment). In either of those cases, payment for the virtual check-in would not be separately payable, but rather it would be bundled into the in-person office visit reimbursement.
- Remote Evaluation of Pre-Recorded Patient Information (Store and Forward). CMS has proposed payment to providers for review of patient generated images and videos for the purposes of assessing whether an in-person office visit is necessary. As with the proposed virtual check-in reimbursement, if a remote evaluation of pre-recorded patient information precedes from, or results in, an in-person office visit, payment would be bundled into the reimbursement for such visit.
- Interprofessional Internet Consultations. CMS has proposed payment to providers for interprofessional consultations occurring via remote communication technology. This would include assessment and management services conducted through telephone, internet, or electronic health record consultations furnished when a patient’s provider requests the opinion and/or treatment advice of a provider with a specific expertise beneficial to the patient.
By proposing the above reimbursement scenarios, CMS aims to increase access for Medicare beneficiaries to telehealth services and improve payment accuracy.
Comments on the Proposed Rule must be submitted by 5:00 p.m. on September 10, 2018.