Medicare Telehealth, Virtual Health Reimbursements Advance
The Centers for Medicare & Medicaid Services (CMS) proposed new telehealth and virtual health codes in the 2020 Physician Fee Schedule rule released July 29, 2019. With this latest proposed regulation, the agency continues to demonstrate a commitment to enabling virtual care delivery.
CMS proposes new telehealth codes
One particular area the agency is working to address is access to services for individuals with opioid use disorders (OUD). The agency proposes three new G codes:
- HCPCS code GYYY1: 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 GYYY2: 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 GYYY3: 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 believes that adding these codes will complement the existing policies related to flexibilities in treating SUDs under Medicare telehealth.
CMS discusses these telehealth codes in conjunction with the newly proposed Medicare Part B benefit for OUDs provided by Outpatient Treatment Programs (OTPS) as well as in the new proposed bundled payment for office-based OUD as well. In establishing this benefit, CMS specifically discusses use of telehealth to expand access to treatment options.
Remote Physiological Monitoring (RPM)
CMS pushes forward with additional, positive changes in RPM reimbursement in 2020:
- CPT 99457 would be used for the first 20 minutes of the treatment management service and then a new code, 994X0, would be used as an add-on code to cover additional 20 minute interval(s) of those services.
- CPT code 994X0 would have a work Relative Value Unit (RVU) of 0.50. CMS proposes direct PE inputs for 994X0.
- For 99457 and 994X0, CMS proposes general supervision. CMS also states that the supervising provider does not need to be the treating provider, but that only the supervising provider may bill Medicare for incident to services.
Online Digital Evaluation Services (e-Visit)
CMS proposes separate payment for six patient-initiated online digital assessments – three codes for individuals who independently bill E/M services and three codes for those who cannot.
- 9X0X1 (Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5–10 minutes). Work RVU of 0.25
- 9X0X2 (Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 11– 20 minutes). Work RVU of 0.50.
- 9X0X3 (Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes). Work RVU of 0.80.
- HCPCS code GNPP1 (Qualified nonphysician healthcare professional online assessment, for an established patient, for up to seven days, cumulative time during the 7 days; 5–10 minutes). Work RVU of 0.25.
- HCPCS code GNPP2 (Qualified nonphysician healthcare professional online assessment service, for an established patient, for up to seven days, cumulative time during the 7 days; 11–20 minutes). Work RVU of 0.44
- HCPCS code GNPP3 (Qualified nonphysician qualified healthcare professional assessment service, for an established patient, for up to seven days, cumulative time during the 7 days; 21 or more minutes). Work RVU of 0.69.
While telehealth/virtual care is a complicated regulatory and reimbursement space, this modality of care delivery is growing in acceptance and delivering on key metrics: ROI, positive patient and physician satisfaction rates, expanded access to care and high quality health outcomes.
If you have yet to start your telehealth and virtual care delivery journey or you are already well along that path, the 2020 proposed PFS provisions are only the latest in a series of new opportunities along that road.
P.S. Read CLA’s entire 2020 Proposed PFS Regulatory Advisor HERE.
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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