CMS has finally issued its 2019 Physician Fee Schedule Proposed Rule. It has highly anticipated new reimbursement policies for telehealth, remote monitoring, with a stronger focus on patient access to health information.
The new codes for Patient Remote Monitoring
The 2019 Proposed Rule offers three codes through which providers can get reimbursements for integrating remote monitoring data into their practice.
The first two are practice expense codes, which include resources providers spend such as office rent, supplies, and medical equipment. The third code tracks the amount of time a care provider spends managing patient care using the remote monitoring data.
- 990X0 – Remote monitoring of physiologic parameter(s). Covers the time providers spend on setting up the technology and explaining to patients how it works.
- 990X1 – Remote monitoring of physiologic parameter(s). Covers device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days.
- 994X9 – Remote physiologic monitoring treatment management services. Covers 20 minutes or more of clinical staff, physician, or other qualified healthcare professional time in a calendar month. The code requires interactive communication with the patient and/or the patient’s caregiver during the month.
There are some challenges in the proposed codes. These codes only cover the exchange and interpretation of “physiologic” data; yet many providers today would agree that there is a wealth of patient data that is helpful at the point of care, including patient-reported outcomes or behavioral data, that would fall outside the definition of physiologic.
Further guidance may be helpful to determine exactly which providers on a care team can spend time working with remote monitoring data. While the code definition states “clinical staff, physician, or other qualified healthcare professional,” elsewhere in the PFS proposed rule refers to the term “practitioner,” which “is used to describe both physicians and non-physician practitioners (NPPs) who are permitted to bill Medicare under the PFS for the services they furnish to Medicare beneficiaries.”
New Reimbursement for “Communication Technology-Based Services”
CMS acknowledges the evolution of physician services furnished through communication technology. So Medicare enacted the telehealth services statutory provision for patients with chronic conditions. Recognizing the many statutory restrictions on telehealth in Section 1834 (m) of the Social Security Act, CMS has taken the interpretation that there are physician services that involve interaction with a patient via remote communication technology that are not considered telehealth services and therefore are not covered by these restrictions.
CMS proposed several new HCPCS codes that are not considered “telehealth” services and as such, not subject to the conditions of Section 1834 (m):
- HCPCS code GVCI1 – Brief Communication Technology-Based Service, e.g. Virtual Check-in. This would include the kinds of brief non-face-to-face check-in services furnished by a physician or other qualified healthcare professional, using communication technology, to evaluate whether or not an office visit or other service is warranted.
- HCPCS code GRAS1 – Remote Evaluation of Pre-Recorded Patient Information. This covers physician time spent reviewing patient-submitted video or images to determine if a follow up visit is needed.
CMS acknowledges modern communication technology that allows for “the kinds of brief check-in services furnished using communication technology that are used to evaluate whether or not an office visit or other service is warranted.”
Beginning January 1, 2019, CMS is proposing to pay providers for utilizing these types of preventative technology services, even in cases where the activity means that a follow-up office visit is not scheduled. Where the check-in services precede an office visit or follow a visit within the previous 7 days, they would be bundled into the payment for the visit, but where the service does not lead to an office visit, there could be a separate payment.
CMS is seeking comments on the implications of this approach, as well as more information from industry about the types of technologies in use today to achieve these goals. Additionally, CMS seeks insight from industry as to if,
- These services are appropriate for new patients
- They are only for existing patients
- Patient consent is required
Health Information Technology to simplify the process
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