CY 2021 Proposed Physician Fee Schedule and White House Executive Order on Improving Rural Health and Telehealth Access

Posted Alliance for Connected Care Post-COVID-19, Press Release

HHS released the Calendar Year 2021 Physician Fee Schedule (PFS), which makes payment and policy changes under Medicare Part B for physicians, with significant telehealth provisions included.  Also, the White House Issued an Executive Order on Improving Rural Health and Telehealth Access.

Physician Fee Schedule

Please find our summary of the PFS here

Please find some topline elements and links below.  

Telehealth Codes

For CY 2021, CMS is proposing to add the following list of services to the Medicare telehealth list on a Category 1 basis. Services added to the Medicare telehealth list on a Category 1 basis are similar to services already on the telehealth list: 

Service TypeHCPCS Code
Visit complexity inherent to evaluation and management associated with primary medical care services that serve as the continuing focal point for all needed health care services GPC1X
Group psychotherapy (other than of a multiple-family group) 90853
Neurobehavioral status exam 96121
Prolonged office or other outpatient evaluation and management service(s) 99XXX
Assessment of and care planning for a patient with cognitive impairment99483
Domiciliary or rest home visit for the evaluation and management of an established patient. Typically, 15 minutes are spent with the patient and/or family or caregiver99334
Domiciliary or rest home visit for the evaluation and management of an established patient. Typically, 25 minutes are spent with the patient and/or family or caregiver99335
Home visit for the evaluation and management of an established patient. Typically, 15 minutes are spent face-to-face with the patient and/or family. 99347
Home visit for the evaluation and management of an established patient. Typically, 25 minutes are spent face-to-face with the patient and/or family.99348

Additionally, CMS is creating a third temporary category of criteria for adding services to the list of Medicare telehealth services. Category 3 describes services added to the Medicare telehealth list during the public health emergency (PHE) for the COVID-19 pandemic that will remain on the list through the calendar year in which the PHE ends. 

RPM Services

  • CMS is clarifying that following the PHE for the COVID-19 pandemic, we will again require that an established patient-physician relationship exist for RPM services to be furnished.
  • CMS is proposing to clarify that RPM services are considered to be evaluation and management (E/M) services.
  • CMS is clarifying that only physicians and NPPs who are eligible to furnish E/M services may bill RPM services.
  • CMS is clarifying that practitioners may furnish RPM services to patients with acute conditions as well as patients with chronic conditions.

Direct Supervision by Interactive Telecommunications Technology 

  • In the CY 2021 PFS proposed rule, CMS is proposing to allow direct supervision to be provided using real-time, interactive audio and video technology (excluding telephone that does not also include video) through December 31, 2021.

Executive Order on Improving Rural Health and Telehealth Access

Key Provisions Include:

  • Launching an Innovative Payment Model to Enable Rural Healthcare Transformation.  Within 30 days of the date of this order, the Secretary of HHS (Secretary) will announce a new model, pursuant to section 1115A of the Social Security Act (42 U.S.C. 1315a), to test innovative payment mechanisms in order to ensure that rural healthcare providers are able to provide the necessary level and quality of care.  This model should give rural providers flexibilities from existing Medicare rules, establish predictable financial payments, and encourage the movement into high-quality, value-based care. (CMMI MODEL)
  • Investments in Physical and Communications Infrastructure.  Within 30 days of the date of this order, the Secretary and the Secretary of Agriculture shall, consistent with applicable law and subject to the availability of appropriations, and in coordination with the Federal Communications Commission and other executive departments and agencies, as appropriate, develop and implement a strategy to improve rural health by improving the physical and communications healthcare infrastructure available to rural Americans.
  • Improving the Health of Rural Americans.  Within 30 days of the date of this order, the Secretary shall submit a report to the President, through the Assistant to the President for Domestic Policy and the Assistant to the President for Economic Policy, regarding existing and upcoming policy initiatives to: (a)  increase rural access to healthcare by eliminating regulatory burdens that limit the availability of clinical professionals; (b)  prevent disease and mortality by developing rural specific efforts to drive improved health outcomes; (c)  reduce maternal mortality and morbidity; and (d)  improve mental health in rural communities.
  • Expanding Flexibilities Beyond the Public Health Emergency.  Within 60 days of the date of this order, the Secretary shall review the following temporary measures put in place during the PHE, and shall propose a regulation to extend these measures, as appropriate, beyond the duration of the PHE:
    • (a)  the additional telehealth services offered to Medicare beneficiaries; and
    • (b)  the services, reporting, staffing, and supervision flexibilities offered to Medicare providers in rural areas.