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CMS Proposes Reimbursement for New Virtual Services

Posted in Legislation and Public Policy, Medicare and Medicaid, Reimbursement Matters

The proposed rule released on July 12 by the Centers for Medicare & Medicaid Services (CMS) would create new billing codes that, if approved, will reimburse physicians for certain virtual interactions with patients. In addition, telehealth services that are already covered by Medicare would be expanded to include prolonged preventive services.Virtual check-in: A new billing code for “brief communication technology-based services,” commonly called “virtual check-in” appointments, would reimburse physicians and other providers for evaluation and management services provided remotely to established patients. Modeled after an existing code that provides for billing of 5-10 minutes of medical discussion by telephone, the new billing code would cover brief medical discussions using other communication modalities. The goal of the new code is to “mitigate the need for potentially unnecessary office visits,” according to CMS. Medicare would pay $14 per visit for virtual check-ins.

Remote evaluation of prerecorded patient information: Asynchronous telemedicine, known as “store & forward” medical care, would now be reimbursable without the use of interactive audio/video or a face-to-face exam. The new code would cover a healthcare provider’s review of “recorded video and/or images captured by a patient in order to evaluate the patient’s condition” in order to determine whether an office visit is necessary. Perhaps the best example of this service is a dermatologist’s remote analysis of a photograph of a skin condition.

Interprofessional internet consultation: This new code would cover reimbursement for peer-to-peer internet or telephone consultations, such as when the patient’s treating physician requests the advice of a specialist without the patient having face-to-face contact with the latter.

The new virtual care codes are not technically considered “telehealth” services, which are defined as remote services furnished in real time using interactive audio or video. CMS is soliciting comments on numerous aspects of the new proposed codes, including possible frequency limitations, how to demonstrate medical necessity, and whether the codes should permit reimbursement for these services when provided to new patients, as well as to established patients.

CMS is soliciting comments on the proposed rule until September 10.

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