CMS proposes to cover the following new telehealth services:
- Store-and-forward: Through store-and-forward applications, patients can send photos or videos of symptoms to their provider and receive treatment advice remotely.
- Brief virtual check-ins: A new type of service conceptualized by CMS, brief virtual check-ins would allow established patients to have a five- to 10-minute, real-time virtual consultation to determine whether their symptoms require an in-person visit. If it replaces an in-person visit, Medicare will cover it as a standalone service. If the patient still needs an office visit, the virtual check in will be considered "bundled" with that visit, and will not be reimbursed separately.
- Internet-based inter-professional consultations: New reimbursement for provider-to-provider consultations via online messaging applications or portals. Both the initiating physician and the consulting physician would be eligible for reimbursement.
- Prolonged preventive services: Reimbursement for preventive care services that require additional time beyond the usual preventive care visit.
- New remote patient monitoring (RPM) codes: Medicare began covering certain RPM services this year. Under the proposal, CMS would expand the RPM codes that it covers, including a code for the initial set-up and patient education associated with an RPM device.
The good news: More reimbursement, fewer geographic restrictions
The proposal could make certain telehealth services a significantly more attractive investment option for providers.
In many cases, CMS is proposing to cover services that physicians are already providing, but that they aren't being reimbursed for, such as provider-to-provider consultations, brief triage conversations with patients, and startup costs associated with RPM devices. New reimbursement for these services could lead to more widespread provider investment.
Notably, CMS is proposing to cover nearly all of these new services (except preventive services) without any geographic or facility restrictions. This approach differs from current Medicare-covered telehealth services, which are limited only to eligible health care facilities and geographic areas. As a result, all providers stand to benefit from the proposal, regardless of location.
The challenge: It's only an incremental increase
Though increased reimbursement is good news, providers will likely be disappointed with CMS' proposed reimbursement rates. CMS is proposing base reimbursement rates of $10 for store-and-forward and $14 for brief virtual check-ins. Inter-professional consultation rates are slightly higher, ranging from $18 to $73.
CMS argues that these low rates are justified because the services require less time and effort than a traditional in-person evaluation and management visit. For systems already offering these services without reimbursement, this is good news; however, organizations looking to invest in new capabilities will have to carefully evaluate whether such low rates justify the costs of a new service offering.
CMS will accept comments on its proposal through September 10, and will issue a final policy in mid-November. In the meantime, providers should prepare for the proposed changes by considering:
- Are there new opportunities to bill for services already offered at the organization?
- Could offering any of the newly covered services help the organization achieve any of its strategic goals?
- Are reimbursement rates for newly covered services sufficient to support the investment required to offer these services?
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