CMS Releases COVID-19 Interim Final Rule: Telehealth, Virtual Health, Audio-Only Communication and More
The Centers for Medicare & Medicaid Services (CMS) released new waiver guidance on March 30. At the same time, CMS released an interim final rule with comment period related to a host of changes. [See graphic for CMS’s overview of these recently announced waivers and flexibilities.]
The following information highlights only a few changes related to telehealth, virtual interactions and audio-only communications across various settings as contained in the Interim Final Rule with Comment Period (IFC).
Telehealth
CMS indicates it will reimburse physicians for telehealth based on the non-facility, clinic rate. CMS adds 80 new CPT codes to the list of approved telehealth codes and lifts the frequency limits on several codes. Further, CMS reiterates that two-way communications can include smartphones using FaceTime or Skype-like applications.
Other Communication Technology-Based Service
For virtual visits, digital online communication codes and remote physiologic monitoring, these may all be provided to new patients in addition to established ones. For remote physiologic monitoring, CMS has temporarily added acute conditions to the current list of chronic conditions for which RPM may be utilized.
Specific to Rural Health Clinics and Federally Qualified Health Centers, CMS opens up reimbursement for several additional codes related to online digital evaluation and management. The codes may also be used with new patients.
Reimbursement for Telephone E/M Codes
A change under the regulation is reimbursement for audio-only communication between a physician/practitioner and a patient. CMS believes that reimbursing for a specific group of telephone E/M codes during this time is the best way to maximize the health care workforce and limit COVID spread.
Physician Supervision Changes in Various Settings
Recognizing the current pandemic, CMS relaxes various physician supervision requirements to allow direct supervision to be provided using real-time interactive audio and video technology when use of such technology is indicated to reduce exposure risks for the beneficiary or health care provider. CMS indicates individual practitioners are in the best position to make these decisions based on their clinical judgement during the pandemic. CMS further discusses this with respect to home health and hospice along with teaching physicians and residents. With the latter, CMS discusses reimbursements and allowances for how this will be treated for purposes of Direction Graduate and Indirect Graduate Medical Education.
And There’s More…
CMS packs a wallop in a short, 229-page rule. The IFC addresses additional policies related to face-to-face visits as well as allowing for therapy and counseling portions, including add-on codes, of the weekly bundles in Opioid Treatment Programs to be furnished using audio-only telephone calls. There are many more details related to all of the above along with flexibilities related to other topics, such as value-based payment programs, Merit-Incentive-Based Payments, Medicare Parts C/D Star Ratings and additional flexibility for ambulance providers among others.
If you or your organization would like to know more, please reach out or connect with your CLA advisor.
P.S. In our previous blog we posted that several MACs were delaying cost report deadlines. We now have blanket CMS waivers for the following:
- Hospital: https://www.cms.gov/files/document/covid-hospitals.pdf
- Teaching Hospital: https://www.cms.gov/files/document/covid-teaching-hospitals.pdf
- Skilled Nursing Facility/Nursing Homes: https://www.cms.gov/files/document/covid-long-term-care-facilities.pdf
- Home Health: https://www.cms.gov/files/document/covid-home-health-agencies.pdf
- Hospice: https://www.cms.gov/files/document/covid-hospices.pdf
- Inpatient Rehab Facility: https://www.cms.gov/files/document/covid-inpatient-rehab-facilities.pdf
- Long-Term Care Hospital: https://www.cms.gov/files/document/covid-long-term-care-hospitals.pdf
- End-Stage Renal Facility: https://www.cms.gov/files/document/covid-19-esrd-facilities.pdf
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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