On Thursday, Centers for Medicare & Medicaid Services (CMS) finalized the Calendar Year 2019 (CY19) Medicare Physician Fee Schedule (PFS), which lays out reimbursement rates for physicians and other health professionals who provide services to Medicare beneficiaries. This year’s rule is another exciting step forward for the telehealth world, with new services like virtual check-ins, store-and-forward, and interprofessional consultations all being reimbursed by Medicare. For the most part, CMS finalized its vision from July’s proposed rule.

Additionally, CMS included provisions related to the recently signed opioids legislation – the SUPPORT for Patients and Communities Act – which will lift cumbersome restrictions on Medicare reimbursement for substance use disorder treatment provided via telehealth.

Key Provisions:

Virtual Check-Ins
CMS finalized its proposal to allow “virtual check-ins” in Medicare, which are 5 to 10 minutes of medical discussion conducted by a provider via communications technology-based services, which include real-time phone and video chat conversations.

The service must be provided to an “established patient” who has seen the treating provider within the past three years, and it may not be related to a service provided within the past seven days nor lead to a service or procedure within the next 24 hours or soonest available appointment. In other words, CMS intends for virtual check-ins to be quick, virtual visits for one-off medical questions and condition assessments, not a follow-up or triage that leads to an office visit.

CMS finalized a code that describes “remote evaluation of recorded video and/or images submitted by an established patient (e.g. store and forward), including interpretation with follow-up with the patient within 24 business hours.” This code has the same seven-day/twenty-four-hour limitations as the virtual check-in code.

The Agency predicts that this reimbursement will be especially useful in specialties like dermatology, wherein patients could take a picture of a skin problem, send it to their doctor, and then receive an interpretation from their doctor within a business day. The beneficiary may be on the hook for cost-sharing related to this service, so CMS is requiring verbal consent from the patient to be noted in the medical record.

Interprofessional Internet Consultations
Interprofessional internet consultations include “assessment and management services conducted through telephone, internet, or electronic health record consultations furnished when a patient’s treating physician or other qualified healthcare professional requests the opinion and/or treatment advice of a consulting physician or qualified health professional with specific specialty expertise.”

By finalizing this proposal, CMS is acknowledging the time and expertise that is required for physicians to consult other physicians and reimbursing them for it. Like the store-and-forward services, the agency is requiring verbal consent from the patient to be noted in the medical record to help avoid any unexpected cost-sharing obligations.

Remote Patient Monitoring
CMS added three new codes to the list of chronic care remote physiologic monitoring CPT codes reimbursable under Medicare. These new codes include remote monitoring of a wireless pulmonary artery sensor and physiologic parameters such as weight, blood pressure, and pulse oximetry. New codes also reimburse for initial set-up and patient education on the remote monitoring equipment provided by the health care professional.

The final rule clarifies that remote patient monitoring may be furnished by clinical staff in addition to physicians, which helps eliminate any uncertainty that a clinic or health system may have about utilizing clinical staff with lower levels of training.

Telehealth Services for Treatment of Substance Use Disorders
The Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act (H.R. 6) removed the originating site geographic requirements included under section 1834(m) of the Social Security Act and adds the home of an individual as a permissible originating site for telehealth services for substance use disorder under Medicare.

In accordance with the SUPPORT Act, CMS issued an interim final rule with comment period for the new originating site rules that are set to go into effect on or after July 1, 2019.

Regulatory Impact Analysis
CMS expects the new telehealth and remote patient monitoring rules to expand access to health care in rural areas, but they estimate that “there will only be a negligible impact on PFS expenditures from these additions.” Once these new rules and codes are implemented, we look forward to using them to further build on evidence showing that outdated regulations on Medicare reimbursement for telehealth services are thwarting opportunities for quality patient care.