S C H E D U L E C Y 2 0 1 9 C H A N G E S T O P H Y S I C ......te ch n ol og y a s se p a ra te...

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CMS PROPOSED TELEHEALTH CHANGES TO PHYSICIAN FEE SCHEDULE CY 2019 On July 12, 2018, the Center for Medicare and Medicaid Services (CMS) published their CY 2019 proposed revisions related to the Physicians Fee Schedule (PFS). Comments on the proposals are due no later than 5 pm on September 10, 2018. The proposal aims to modernize the healthcare system and help “restore the doctor-patient relationship” by reducing administrative burden. The changes related to telehealth are significant, as it not only expands Medicare telehealth services, but communicates a new interpretation by CMS of the applicability of their statutory requirements for reimbursement of remote communication technology as separate from telehealth, and adds new services based on this interpretation. For a more detailed analysis of these proposals, visit CCHP's website at cchpca.org. Brief Communication Technology-based Service, e.g. Virtual Check-in Asynchronous Remote Evaluation of Pre- Recorded Patient Information Interprofessional Internet Consultation Additional Proposals When a physician or other qualified health care professional has a brief non-face-to- face check-in with a patient via communication technology to assess whether the patient’s condition necessitates an office visit Reimbursed at $14 Proposed code GCVI1 Not labeled telehealth, therefore not subject to telehealth restrictions FQHC/RHCs will receive own code for this service Remote professional evaluation of patient-transmitted information conducted via pre-recorded “store and forward” video or image technology Proposed Code GRAS1 Reimbursed calculated by CMS through direct crosswalk to CPT code 93793 which in 2018 paid $12.24 Not labled telehealth, therefore not subject to telehealth restrictions FQHC/RHCs will receive own code for this service Cover consultations between professionals performed via communications technology such as telephone or Internet 99446-99449 994X0 994X6 Value of each code to be established Verbal consent from patient would be required Add HCPCS codes G0513 and G0514 as codes to be reimbursed if telehealth is used. Would be subject to the telehealth restrictions. Made changes required by Bipartisan Budget Act of 2018 For remote pyshiological monitoring: codes created and proposed to be reimbursed: 990X0, 990X1 and 990X9 For chronic care management: new code for reimbursement 994X7 CCHP was created in 2008 by the California Health Care Foundation, who remains its lead funder. The National Telehealth Policy Resource Center project is made possible by Grant #G22RH30365 from the Office for the Advancement of Telehealth, Health Resources and Services Administration, DHHS. Copyrighted 2018 Center for Connected Health Policy/Public Health Institute MANAGEMENT AND COUNSELING TREATMENT FOR SUBSTANCE USE DISORDER CMS is considering developing separate bundled payment for an episode of care for treatment of Substance Use Disorders (SUD), which can include elements of Medication Assisted Therapy (MAT), including potentially web- based routine counseling. They reason that “creating separate payment for a bundled episode of care for components of MAT … under the PFS could provide opportunities to better leverage services furnished with communication technology while expanding access to treatment for SUDs.” It could also help alleviate the need for more acute services and prevent hospital readmissions.

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CMS PROPOSED TELEHEALTHCHANGES TO PHYSICIAN FEE

SCHEDULE CY 2019 On July 12, 2018, the Center for Medicare and Medicaid

Services (CMS) published their CY 2019 proposedrevisions related to the Physicians Fee Schedule (PFS).Comments on the proposals are due no later than 5pm on September 10, 2018. The proposal aims tomodernize the healthcare system and help “restore thedoctor-patient relationship” by reducing administrative burden.  The changes related to telehealth aresignificant, as it not only expands Medicare telehealthservices, but communicates a new interpretation byCMS of the applicability of their statutory requirementsfor reimbursement of remote communicationtechnology as separate from telehealth, and adds newservices based on this interpretation.  For a moredetailed analysis of these proposals, visit CCHP'swebsite at cchpca.org.

Brief CommunicationTechnology-based

Service, e.g. VirtualCheck-in

Asynchronous RemoteEvaluation of Pre-Recorded Patient

Information

InterprofessionalInternet Consultation

Additional Proposals

When a physicianor other qualifiedhealth careprofessional has a brief non-face-to-face check-in with apatient viacommunicationtechnology to assess whether thepatient’s conditionnecessitates anoffice visit 

Reimbursed at $14 Proposed code

GCVI1 Not labeled

telehealth,therefore notsubject totelehealthrestrictions 

FQHC/RHCs willreceive own codefor this service

Remote professionalevaluation ofpatient-transmittedinformationconducted via pre-recorded “storeand forward” videoor imagetechnology

Proposed CodeGRAS1

Reimbursedcalculated by CMSthrough direct crosswalk to CPTcode 93793 whichin 2018 paid $12.24

Not labledtelehealth,therefore notsubject totelehealthrestrictions

FQHC/RHCs willreceive own codefor this service

Cover consultationsbetweenprofessionalsperformed viacommunicationstechnology such as telephoneor Internet

99446-99449 994X0 

994X6   Value of each code

to be established Verbal consent from

patient would berequired

Add HCPCS codesG0513 and G0514 ascodes to bereimbursed iftelehealth is used.Would be subject tothe telehealthrestrictions.

Made changesrequired byBipartisan BudgetAct of 2018

For remotepyshiologicalmonitoring: codescreated andproposed to bereimbursed:  990X0,990X1 and 990X9

For chronic caremanagement: newcode forreimbursement994X7 

CCHP was created in 2008 by the California Health Care Foundation, who remains its lead funder. The National Telehealth Policy Resource Center project is made possible by Grant #G22RH30365 from the Office for the

Advancement of Telehealth, Health Resources and Services Administration, DHHS. Copyrighted 2018 Center for Connected Health Policy/Public Health Institute

MANAGEMENT AND COUNSELING TREATMENT  FOR SUBSTANCE USE DISORDER CMS is considering developing separate bundled payment for an episode of care for treatment of Substance UseDisorders (SUD), which can include elements of Medication Assisted Therapy (MAT), including potentially web-based routine counseling.  They reason that “creating separate payment for a bundled episode of care forcomponents of MAT … under the PFS could provide opportunities to better leverage services furnished withcommunication technology while expanding access to treatment for SUDs.”  It could also help alleviate the need formore acute services and prevent hospital readmissions.