CMS Advances New Virtual, Telehealth Reimbursements
In the final 2020 Physician Fee Schedule (PFS) rule released on November 1, the Centers for Medicare & Medicare Services (CMS) provides more opportunities for telehealth and virtual health. Let’s take a quick look.
CMS finalized three specific opioid use disorder (OUD) telehealth codes. Those are:
- HCPCS code G2086: Office-based treatment for opioid use disorder including development of the treatment plan, care coordination, individual therapy and group therapy and counseling; at least 70 minutes in the first calendar month.
- HCPCS code G2087: Office-based treatment for opioid use disorder, including care coordination, individual therapy and group therapy and counseling; at least 60 minutes in a subsequent calendar month.
- HCPCS code G2088: Office-based treatment for opioid use disorder, including care coordination, individual therapy and group therapy and counseling; each additional 30 minutes beyond the first 120 minutes (list separately in addition to code for primary procedure).
CMS referenced these codes in conjunction with the statutory requirements under the Substance Use–Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities (SUPPORT) Act, which remove geographic limitations for telehealth services furnished to individuals diagnosed with a SUD for the purpose of treating the SUD or a co-occurring mental health disorder. The SUPPORT Act also allows for a patient’s home to be an originating site. CMS believes the new OUD telehealth codes will complement the SUPPORT Act changes which have already been finalized.
CMS made important improvements in remote physiological monitoring (RPM). CMS approved an add-on code (99458) for RPM and will allow both 99457 and 99458 to fall under general supervision. The final code descriptors are:
- CPT code 99457 (Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; initial 20 minutes)
- CPT code 99458 (Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; additional 20 minutes). CMS finalized a RVU of 0.61 and finalized the RUC-recommended direct PE.
CMS did not make reimbursement or coding changes to its previously finalized codes on virtual communications (G2010 and G2012) or the six interprofessional codes (99446 – 99449, 99451, 99452), but did adjust the beneficiary consent requirements. CMS had previously required advance beneficiary consent be obtained every time a service was to be used. Stakeholders expressed concern with the burden and difficulty in repeatedly obtaining these consents. In the final 2020 PFS rule, CMS allows a single consent be obtained at least annually for these services.
Finally, with respect to online digital evaluations (e-visits), CMS also adopted new codes, which stem from changes approved in September 2018 by the American Medical Association (AMA) Current Procedural Terminology (CPT) Editorial Panel. Those changes deleted two existing codes and replaced them with six new non-face-to face codes. These new codes describe patient-initiated digital communications that require a clinical decision that otherwise typically would have been provided in the office. Three of the codes are for individuals who independently bill evaluation and management services (99420-99422) and three codes for those who cannot (98970-98972). For 2020, CMS finalized separate payment for these online digital assessment codes as well as corresponding G codes.
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Jennifer Boese is the Director of Health Care Policy at CLA. She is a highly successful public policy, legislative, advocacy and political affairs leader, including working in both the state and federal government as well as the private sector. She brings over 20 years of government relations and public policy knowledge with her to CLA. Well over half of her career has been spent dedicated to health care policy and the health care industry, affording her a deep understanding of the health care market and environment, health care organizations and health care stakeholders. Her role at CLA is to provide thought leadership, policy analysis and strategic insights to health care providers across the continuum related to the industry's ongoing transformation towards value. A key focus of that work is on market innovations and emerging payment models. Her goal is to help CLA clients navigate and thrive in an increasingly dynamic health care environment.
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