2021 Medicare Physician Fee Schedule Telehealth Expands Beyond CV-19

Your telephone, telehealth exam, and virtual check-in pay could come to a grinding halt unless you’re up to date on the latest potentially upcoming changes to the 2021 Medicare Physician Fee Schedule. Auditors will be checking to see if you tightened your regulations for coding, compliance and more. Prep your practice now on the top telehealth changes that could be coming down the pike and remain way past the pandemic.

The proposed CMS Fee Schedule for 2021 chocked full of telemedicine updates that could extend beyond the coronavirus public health emergency was released on August 3. Now’s your chance to provide your insight on payments and requirements that are being floated for potential changes to 2021 Medicare Physician Fee Schedule Telehealth services and coverage during COVID-19 and beyond. You have until only two months to have your voice heard. 2021 Medicare Physician Fee Schedule Telehealth.

But only if you know the intended changes …

Not All Telehealth Payments Are Permanent

The pandemic increased telemedicine visits for more than 70% of practice, including ones like yours. Your usage made CMS see the long-term benefits of treating patients outside the office, and make plans to extend some allowances even after 2020 and the pandemic’s end. Look at the following list of codes that Medicare intends on adding to its permanent telehealth list. If you see ones you want added beyond the following services, now is the time to alert CMS.

Prolonged Services: 99xxx
Group Psychotherapy: 90853
Neurobehavioral Status Exam: 96121
Domiciliary, Rest Home, or Custodial Care Services: 99335
Care Planning for Patients with Cognitive Impairment: 99483
Home Visits: 99347, 99348

You’re also potentially going to have to wrap your head around a new category of telemedicine codes. CMS is considering approving payment for these services through the end of the calendar year that the public health emergency ends. This proposed new tier — Category 3 — may include the following HCPCS codes:

99281, 99282, 99283: Emergency Department Visits
96130, 96131, 96132, 96133: Psychological and Neuropsychological Testing
99315, 99316: Nursing Facilities Discharge Day Management
99336, 99337: Domiciliary, Rest Home, or Custodial Care services, Established Patients
99349, 99350: Home Visits, Established Patients

For Telehealth Services, Provider Type and Location Matter

For the duration of the pandemic, CMS has greatly expanded the types of providers who can bill telehealth and other remote services. Providers including licensed clinical social workers, clinical psychologists, physical therapists, occupational therapists, and speech-language pathologists are able to provide remote evaluation services, including virtual check-ins and brief online assessments.

Now, CMS is proposing to add two new G codes for those provider types to use when billing for the remote evaluation of patient-submitted video, images, and virtual check-ins (which you’d currently code using G2010 and G2012).

In the proposed 2021 Medicare Physician Fee Schedule, CMS has also clarified that you are not to code services as telehealth simply because the patient and provider are not face-to-face. For example, if the patient and provider are in the same location/setting, yet using (audio or video) methods to communicate in order to avoid exposure risks of COVID-19, telehealth rules do not apply. The patient and provider must be in different physical locations.

Payment for Audio-Only E/M Services Could Be Permanent

Just because the public health emergency will eventually end doesn’t mean your patients will stop wanting to decrease in-office visits to prevent exposure to diseases. Nor does every patient have access to video communication. Therefore, while CMS is not proposing to make the telephone E/M codes permanent telehealth codes, they are requesting comment as to whether you think you would like a permanent code and payment for an audio-only service. 2021 Medicare Physician Fee Schedule Telehealth.

CMS is suggesting that the proposed phone code be similar to a virtual check-in but for a longer length of time (and thus, a higher payment). Be sure to share your input as to the optimal duration of the service, plus what types of resources and expenses you face for providing such a service.

Requirements for Remote Physiologic Monitoring Set to Tighten

You may have gotten slack about your telemedicine regulatory requirements and CMS is now stressing that you better reexamine your habits. The COVID-19 pandemic allowed you to temporarily loosen many of your telehealth regulations, but that will end soon. For payment year 2021, CMS is alerting providers that they will begin heightened enforcement of the following remote physiologic monitoring (RPM) requirements:

Established Patient-Physician Status: You may provide RPM services to patients only when you have an existing relationship. During the PHE, CMS opened the service to new patients too.
On-Demand Agreement: You may continue to obtain patient consent for RPM services at the time services are provided (you do not have to obtain consent beforehand).
Nurse-Allowed Supervised Monitoring: As in the pandemic, auxiliary staff such as licensed practicing nurses and medical assistants, as well as contracted employees, may provide RPM services under a physician’s supervision. Use codes 99453 and 99454.
NPP and MD Restricted: Only physicians and non-physician practitioners (NPPs) (e.g., Nurse Practitioners) who are able to bill E/M services may bill for RPM service (because CMS considers RPM services to be E/M services).
All Diagnoses Eligible: You may furnish RPM services to patients with both acute and chronic conditions.
Automated Data Required: Any medical device you furnish to a patient for payable RPM services must automatically report data (patients cannot self-report), and must meet certain FDA requirements.

Physicians May Provide Direct Supervision Remotely

Your supervision definitions have done a 180 under COVID – and will be sticking that way. Pre-coronavirus, direct supervision required that the supervising physician be physically present in the same location, immediately available, and able to provide assistance and direction through the procedure if needed.

During the COVID-19 public health emergency, CMS allowed physicians and NPPs to provide direct supervision virtually (using real-time, interactive audio/video communication, for example) in order to reduce virus exposure risk to providers and patients. Provided that the 2021 MPFS proposed supervision rule is approved, your providers can continue to provide direct supervision virtually through at least Dec. 31, 2021.

Source: Proposed Changes to the Medicare Physician Fee Schedule for Calendar Year 2021 You can submit comments to CMS until Oct. 5, 2020.