Updated 2019 Medicare Telemedicine Policy and Telehealth Payment

Several months ago, the Centers for Medicare & Medicaid Services (CMS) released an updated Medicare telemedicine policy for Medicare, which went into effect on Jan. 1, 2019.

The new changes in the CMS’ finalized Calendar Year 2019 Physician Fee Schedule for Medicare telemedicine policy are brought with the goal of streamlining the healthcare system, and reducing the administration load, thus improving the doctor-patient relationship.

The updated Medicare telemedicine policy also addresses telemedicine reimbursement, particularly expanding it. This is because the requirements of the Social Security Act statute may be limiting the coding for new telemedicine services and their reimbursement.

Here are all the changes CMS made in the Medicare telemedicine policy, including some that take effect on or after July 1, 2019.

Review New Medicare Telemedicine CPT© Codes for 2019

The Social Security Act statute limits the use of telehealth to geographical locations, healthcare services, healthcare providers, and communication technology. The limitations concern services such as office visits, professional consultations, and office psychiatry services. All those services are billed as regular in-person meetings between healthcare providers and patients.

However, the limitations don’t concern services that are provided remotely with the help of various kinds of remote communication technology. They are not considered “Medicare telehealth services.”

Therefore, CMS updated the telehealth policy for Medicare by adding new telehealth CPT^©codes and HCPCS codes regarding telemedicine reimbursement. The new telemedicine CPT codes and HCPCS codes address telemedicine reimbursement for:

Brief Communication Technology-Based Service, or Virtual Check-Ins (HCPCS code G2012) FQHCs (Federally Qualified Health Centers) and RHCs (Rural Health Centers) are now able to get reimbursed for brief interactions with patients over the phone or live video when assessing whether the patients should come in for an office visit. This improves convenience and efficiency for both healthcare providers and patients.
Remote Evaluation of Pre-Recorded Patient Information (HCPCS code G2010) FQHCs and RHCs can now also get telemedicine reimbursement for remote patient evaluations when patients initiate consultations by sending pre-recorded videos or images containing patient information.
Interprofessional Internet Consultation (CPT codes 99452, 99451, 99446, 99447, 99448, and 99449) The codes can cover consultations between professionals conducted via the internet or a phone call, and both professionals will be reimbursed. However, interprofessional internet consultation services are limited to healthcare practitioners who can independently get reimbursements from Medicare for evaluation and management visits. These telehealth billing codes don’t apply to FQHCs and RHCs.

Recognize Extended Medicare Telehealth Policy Codes and Facility Restrictions

CMS added several more rules and codes to its Medicare telehealth policy, including:

Prolonged Preventive Services (HCPCS codes G0513 and G0514)
Remote Physiologic Monitoring (CPT codes 99453, 99454, and 99457)
Chronic Care Management (CPT code 99491)

The Medicare telehealth policy also includes new facility restrictions for telemedicine reimbursement regarding:

ESRD (End Stage Renal Disease) services – The home and renal dialysis facilities qualify now as eligible originating sites for reimbursement. If the originating site is the home, no facility fees will incur.
Acute stroke treatment – Any mobile stroke unit and other eligible originating sites can now get telemedicine reimbursement when it comes to treating acute stroke. Geographic limitations won’t apply for the treatment in eligible originating sites.
Treatment for substance use disorders (SUDs) –CMS also updated the policy for the reimbursement of treating patients with SUDs and other co-occurring mental health disorders.

There are now no geographic requirements for Medicare telehealth originating sites. This takes effect on or after July 1, 2019.

Expect Telemedicine Reimbursement for Medicare Advantage Plans

CMS also addressed changes for Medicare Advantage (MA) plans, allowing MA to provide “additional telehealth benefits” and treat them as basic benefits. However, this comes with specific telemedicine compliance requirements.

To achieve full telemedicine and HIPAA compliance, MA plans need to:

Make additional telehealth benefits available as in-person services as well
Make sure that additional telehealth services meet the same requirements regarding coverage and access that basic services have
Use their provider directory
Comply with requirements regarding evaluating and selecting providers
Use only contracted providers to provide additional telehealth benefits
Provide CMS with additional telehealth benefits information
Comply with the laws for the practice of medicine

If an MA plan doesn’t comply with the requirements for treating additional telehealth benefits as basic benefits, the plan must treat those benefits as supplemental. This is all under the Bipartisan Budget Act of 2018, which goes into effect in 2020. The current restrictions by Medicare will not apply to all these new changes regarding Medicare Advantage plans and additional telehealth benefits.

Make sure your healthcare organization meets all of the requirements for the new telemedicine coding compliance changes. If you’re a HIPAA-covered entity, make sure you take the time to additionally explore all the new changes regarding telemedicine and HIPAA compliance, so that you can make sure you follow all the necessary regulations.

For help understanding and complying with the complex regulations, we’re here for you. Training Leader can help you easily stay compliant, and make sure your organization is efficient and successful. Contact us today, and we’ll be more than happy to help you succeed.