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Proposed Medicare Physician Fee Schedule Would Extend Telehealth Flexibilities and Add New Coverage

Dr. M Telehealth — Wed, 14 Aug 2024 22:14:36 +0000

Summary Points
The Centers for Medicare & Medicaid Services (CMS) released its annual proposed rule updating the Medicare Physician Fee Schedule (MPFS) for calendar year (CY) 2025.¹ The proposed rule includes various provisions related to telehealth service delivery and other virtual care modalities. Similar to recent proposed rules, many of the provisions seek to extend temporary telehealth and virtual care flexibilities implemented since the COVID-19 public health emergency through the end of CY2025. Notably, for the first time CMS is proposing coverage for dispensing and monitoring of innovative digital mental health technologies.

Summary Points

The Centers for Medicare & Medicaid Services (CMS) released its annual proposed rule updating the Medicare Physician Fee Schedule (MPFS) for calendar year (CY) 2025.¹
The proposed rule includes various provisions related to telehealth service delivery and other virtual care modalities. Similar to recent proposed rules, many of the provisions seek to extend temporary telehealth and virtual care flexibilities implemented since the COVID-19 public health emergency through the end of CY2025.
Notably, for the first time CMS is proposing coverage for dispensing and monitoring of innovative digital mental health technologies.

General Telehealth-Related Provisions

Medicare Telehealth Services List

CMS is proposing to add the following services to the Medicare Telehealth Services List:

On a provisional basis: Anticoagulation management monitoring (i.e., Home International Normalized Ratio monitoring) and related caregiver training; and,
On a permanent basis: Individual counseling for pre-exposure prophylaxis (PrEP) for Human Immunodeficiency Virus (HIV).

CMS decided not to recategorize any existing provisional codes as permanent until they can complete a comprehensive review of all provisional codes. This is expected to be addressed in future rulemaking.

New CPT Codes for Audio-Visual and Audio-Only Telehealth Services

In February 2023, the American Medical Association’s CPT Editorial Panel added seventeen new CPT codes for reporting telehealth office visits, eight synchronous audio video services, eight synchronous audio-only services and one code for an asynchronous virtual check-in service.

CMS is proposing not to recognize the new synchronous audio-video or audio-only CPT codes for telehealth services provided to Medicare patients at this time, citing similarity to existing codes and its interpretation of section 1834(m) of the Social Security Act requiring payment parity for a telehealth delivered service that is equivalent to an in-person delivered service. Thus, providers would continue to report the same codes for in-person office visits and use modifiers to indicate if the patient was home and/or if the visit was audio-only. CMS proposed accepting the CPT Panel’s recommendation related to adopting the asynchronous virtual check-in code as a replacement for an existing code.

The CPT Panel also proposed deleting three codes (99441–99443) for reporting telephone evaluation and management (E/M) services. These codes are assigned provisional status on the Medicare Telehealth Services List and would return to bundled status when current telehealth flexibilities expire on December 31, 2024.

Audio-Only Communication Technology

CMS’ previous definition of “interactive communication system” excluded audio-only technologies. CMS is proposing that the definition of an interactive telecommunications system will be expanded to include audio-only technology only in cases where the patient is unable or does not want to use video.

CMS would require providers to append a modifier (“93” or “FQ,”) to claims for services that meet these criteria to verify that the conditions have been met.

Interprofessional Consultation

CMS is proposing six new codes for interprofessional consultation that can be billed by providers who cannot independently bill Medicare for E/M visits (e.g., clinical psychologists, clinical social workers, marriage and family therapists, and mental health counselors). Providers would need to obtain patient consent in advance of these services. The new codes would facilitate interprofessional consultations between treating/requesting practitioners and consultant practitioners. This proposed payment is consistent with CMS’ efforts to recognize and reflect behavioral health care within the Physician Fee Schedule and allows for compensation for consulting practitioners.

Extending Temporary Policies Through CY 2025.

Distant Site Requirements: Would continue to allow practitioners to bill using their currently enrolled practice site instead of their home address when the practitioner’s home is the distant site for a telehealth visit.
Direct Supervision via Use of Two-way Audio/Video Communications Technology: Would continue defining “direct supervision,” for purposes of Medicare billing by supervising practitioners, to include supervision via audio-video communications technology (excluding audio-only).
Frequency Limitations on Medicare Telehealth Subsequent Care Services in Inpatient and Nursing Facility Settings, and Critical Care Consultations: Would continue the suspension of frequency limitations for subsequent inpatient visits, subsequent nursing visits, and critical care consultations.
Federally Qualified Health Centers (FQHCs) and Rural Health Centers (RHCs).In alignment with the virtual supervision proposed rules described above, CMS is proposing to continue defining “direct supervision” to include audio-video communications technology (excluding audio-only) for FQHCs and RHCs. CMS also proposes to temporarily allow payment for non-behavioral health visits furnished via telehealth through the end of 2025 using HCPCS code G2025. Lastly, CMS proposes to continue delaying the in-person visit requirement for mental health services delivered via communication technology by FQHCs and RHCs to beneficiaries in their homes until January 1, 2026; the requirement is currently slated to go back into effect on January 1, 2025.
Teaching Physician Billing for Services Involving Residents with Virtual Presence:Would continue allowing teaching physicians to have a virtual presence (via real-time audio-visual observation, excluding audio-only) in all teaching settings but only in clinical instances when the service is furnished virtually (for example, a three-way telehealth visit with all parties in separate locations).

Telehealth Originating Site Facility Fee Payment Amount Update

CMS is proposing to increase the telehealth originating site facility fee payment from $26.96 in 2024 to $31.04 for 2025.

Mental Health-Related Provisions

Digital Mental Health Treatment Devices

CMS is proposing new policies to cover digital mental health treatment (DMHT) devices used in conjunction with ongoing behavioral health care treatment.

CMS previously indicated that digital therapeutics did not have a Medicare benefit category. Now, CMS is proposing to adopt three new codes that would give Medicare beneficiaries access to the service. CMS notes that DMHT can “offer innovative means to access certain behavioral health care services,” particularly in light of behavioral health workforce shortages and increased demand. The proposal applies only to the use of DMHT devices that have been cleared by the FDA.

To effectuate coverage, CMS is proposing to create a three-code series of CPT codes, modeled on codes currently in use for remote therapeutic monitoring (RTM).

The first, GMBT1, would be used for “supply of digital mental health treatment device and initial education and onboarding, per course of treatment that augments a behavioral therapy plan.” Noting “pricing variability” of various devices, CMS does not propose a price for the code, but suggests instead that GMBT1 be local contractor priced and seeks comment on potential national pricing.
Two other codes will support the follow-on use of DMHT: GMBT2 for the first 20 minutes of treatment management services related to the use of the DMHT, and GMBT3 for subsequent additional 20 minutes. These two codes would support billing for professional time spent reviewing data generated from the DMHT device from patient observations and patient specific inputs in a calendar month. They require at least one interactive communication with the patient, or the patient’s caregiver, during the calendar month. Pricing for the codes is based on pricing for the comparable treatment management services for RTM.

Telecommunication Flexibilities for Treatment with Methadone

In an effort to address significant barriers many patients face in initiating and participating in opioid use disorder (OUD) treatment services, CMS is proposing new flexibilities for OUD treatment services furnished via telecommunications by opioid treatment programs (OTPs), as long as the technologies being used are permitted under applicable requirements from the Substance Abuse and Mental Health Services Administration and the Drug Enforcement Administration at the time of service provision and all other applicable requirements are met. Specifically, CMS is proposing to allow periodic assessments to be furnished via audio-only starting January 1, 2025, as long as all other applicable requirements are met. The agency is also proposing to allow the OTP intake add-on code (HCPCS code G2076) to be furnished via two-way audio-video communications technology when billed for the initiation of treatment.

Safety Planning Interventions (SPI) and Post-Discharge Telephonic Follow-up Contacts Intervention (FCI)

CMS is proposing payment mechanisms and coding for SPI and post-discharge FCI for interventions initiated or provided to patients with risk of suicide. The coding is being proposed due to a lack of adequate payment mechanisms and billing codes for these interventions, which contributes to inadequate compensation and inconsistency of service.

Post-discharge telephonic FCI is a protocol for individuals with suicide risk where providers make a series of telephone contacts in the weeks or months following discharge from the emergency department or other care settings. They are currently not within the scope of Medicare telehealth services and are under-utilized. The proposed code for FCI is for a bundled service with four calls per month lasting 10–20 minutes and would require patient consent. The RVU value is based on the CPT code for principal care management. CMS is seeking comment as to the appropriate duration of service and the actual contact threshold for billing.

Next Steps

CMS is seeking comments to the CY 2025 MPFS by September 9, 2024. The final rule will be released in early November, and the majority of provisions (if adopted as final) will take effect on Jan. 1, 2025. Stay tuned later this Fall, when Manatt on Health will publish a summary of the final rule.

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AMERICAN TELEMEDICINE ASSOCIATION LAUNCHES THREE NEW TOOLS TO ADVANCE TELEHEALTH’S ROLE IN ADDRESSING HEALTH DISPARITIES

Dr. M. Rosen — Mon, 18 Sep 2023 14:42:26 +0000

Washington, D.C., September 18, 2023 – The American Telemedicine Association (ATA) announced this week that its CEO’s Advisory Group on Using Telehealth to Eliminate Disparities and Inequities is releasing three new tools this week, to inform ways in which telehealth can impact disparities and inequities.

“We launched the advisory group in 2021 to address the unique ways telehealth could be used to eliminate health disparities in the U.S. We are confident that the tools we are launching this week will support decision-making related to targeting and funding interventions that improve health in communities,” said Ann Mond Johnson, CEO of the ATA. “Our Advisory Group is comprised of national healthcare leaders uniquely focused on health disparities. Led by co-chairs Kristi Henderson, DNP, Yasmine Winkler and Ron Wyatt, MD, and facilitated by David Smith, CEO of Third Horizon Strategies, their groundbreaking work will further position our community to leverage telehealth to eliminate healthcare disparities.”

All three tools were released today, to commemorate the third annual Telehealth Awareness Week. This year’s events will highlight the value telehealth brings to patients and helps to expand access to quality care, how virtual care is addressing many of the challenges faced by healthcare providers, and its role in building a modern, omnichannel care delivery system.

The Digital Infrastructure Disparities Score and Map uses a newly created composite measure designed to score a community’s digital infrastructure on a scale of 1-100.
The Economic and Social Value-Added Calculator tool is designed to scope the cost of telehealth-based clinical or social interventions, including estimates for the total value of an intervention created in favor of payers, providers, government, and business. The calculator analyzes the capital and operating costs for these interventions, including technology platforms (telehealth solutions) and funding needed to ensure community members have solid, reliable, and contiguous broadband connectivity.
The third tool is a toolkit summarizing all resources the group has released to date, including a new roadmap to address inequalities in the delivery of healthcare information and services with a focus on both access and improving outcomes.

Access the above tools here: Disparities Advisory Group Toolkit.

“These new tools build on a framework and advance our efforts to ensure everyone is able to access needed care, recognizing that telehealth is a critical component and a modality for accessing care,” added Kristi Henderson, DNP, CEO of Confluent Health, chair of the ATA Board of Directors, and co-chair of the advisory group. “The work of our advisory group focuses on creating the infrastructures and tools to allow the industry – including healthcare providers, payers and policymakers – to appropriately assess the required components in eliminating disparities, and to understand where virtual care services can help to improve the health of our citizens and the requisite investment. These tools also look beyond the traditional return on investment framework to a broader notion of economic and social value-added. The advisory group believes the economic burden of inaction should be enough to galvanize all stakeholders towards leveraging the tools necessary to eliminate inequities in care.”

Webinar Alert: Digital Disparities and Re-thinking Economic and Social Value Creation

On September 19, the ATA will host a webinar featuring a discussion with the three co-chairs of the CEO’s Advisory Group on Using Telehealth to Eliminate Disparities and Inequities, who will share their thoughts on creating digitally-centric interventions that can deliver true economic and social value across communities.– Panelists: Kristi Henderson, DNP, Confluent Health and ATA Board chair; Yasmine Winkler, managed care executive and secretary of the ATA Board; and Ron Wyatt, MD, Achieving Equity, LLC, with David Smith, Third Horizon Strategies. Register for the webinar, here.

About the ATA

As the only organization completely focused on advancing telehealth, the American Telemedicine Association is committed to ensuring that everyone has access to safe, affordable, and appropriate care when and where they need it, enabling the system to do more good for more people. The ATA represents a broad and inclusive member network of leading healthcare delivery systems, academic institutions, technology solution providers and payers, as well as partner organizations and alliances, working to advance industry adoption of telehealth, promote responsible policy, advocate for government and market normalization, and provide education and resources to help integrate virtual care into emerging value-based delivery models.

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ATA Releases Data Privacy Principles for Telehealth Practices

Dr. M. Rosen — Thu, 31 Aug 2023 19:02:07 +0000

August 31, 2023 – Amid rising concerns about data privacy within the telehealth arena, the American Telemedicine Association (ATA) released a set of principles to ensure patient data is protected during telehealth utilization.

The ATA’s Health Data Privacy Principles include six components: consistency, the definition of consumer health data, the Health Insurance Portability and Accountability Act (HIPAA), consumer rights, consumer consent, sale of data and opt-out, and enforcement.

The ATA states that a federal policy would offer much-needed consistency in data privacy practices for telehealth providers nationwide. But in lieu of such a policy, there need to be efforts to establish uniformity with existing federal and state privacy laws and standards to reduce compliance challenges and confusion.

Dig Deeper

In addition, state laws should define consumer health data and other common terms for protected health information using language similar to HIPAA and exempt HIPAA-covered entities and their business associates from state privacy laws that differ from HIPAA standards.

“HIPAA is a proven, decades-old data privacy framework,” the ATA states. “Requiring HIPAA-covered entities to adhere to additional layers of state privacy laws would negatively impact their ability to deliver services, increase compliance costs, and stymie innovation.”

The ATA also emphasized the importance of consumer rights and consent. The association noted that consumers should have “a right to notice, a right to access, a right to correct, a right to portability, a right to delete” their data as long as the rights are consistent with other medical record retention laws and include legal exceptions.

Further, the ATA stated that consumers should be provided with clear disclosures on the patient data that is collected, how it will be used, and how to opt out of processing.

Finally, state attorneys general should be empowered to act when privacy laws are violated, the ATA stated. But, the association also noted that data privacy policies should not allow for private rights of action as they can result in frivolous lawsuits and out-of-court settlements.

“As states adopt privacy statutes and regulations, establishing uniformity with existing federal and other state standards would reduce both complexity of compliance and confusion for consumers and companies alike. Privacy laws should allow for innovation and the advancement of technology-assisted care,” said Kyle Zebley, senior vice president of public policy at the ATA, in the press release. “The ATA supports efforts to ensure telehealth practices meet standards for patient safety, data privacy, and information security, while advancing patient access and building awareness of telehealth practices.”

Concerns around data security on telehealth platforms have been steadily increasing.

In March, telehealth company Cerebral reported a healthcare data breach impacting more than 3.1 million individuals. The breach was related to the company’s use of tracking pixels.

This report came just one month after Senators Amy Klobuchar (D-MN), Susan Collins (R-ME), Maria Cantwell (D-WA), and Cynthia Lummis (R-WY) sent letters to three telehealth companies, including Cerebral, detailing concerns over the companies’ health data privacy practices. In the letter to Cerebral, the senators noted that the company’s website claims that information entered on intake forms “is confidential and secure,” but “this information is reportedly sent to advertising platforms, along with the information needed to identify users.”

Amid the growing focus on data privacy in telehealth this year, the public health emergency (PHE) declaration ended, eliminating the Notifications of Enforcement Discretion issued under HIPAA and the Health Information Technology for Economic and Clinical Health (HITECH) Act during the pandemic.

The HHS Office for Civil Rights (OCR) issued four notifications that loosened HIPAA compliance obligations, including allowing telehealth providers to use non-public-facing communication technologies like Zoom and Skype.

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PointClickCare (PCC) Integration with Nonagon N9+ Device and Virtual Exam Platform – Resident Dashboard – Clinical Tab – Weights Vitals

Dr. M. Rosen — Thu, 31 Aug 2023 18:20:16 +0000

PointClickCare (PCC) Integration with Nonagon N9+ Device and Virtual Exam Platform – Resident Dashboard – Clinical Tab – Weights Vitals

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PointClickCare (PCC) Integration with Nonagon N9+ Device and Virtual Exam Platform – Resident Dashboard – Clinical Tab

Dr. M. Rosen — Thu, 31 Aug 2023 18:17:09 +0000

PointClickCare (PCC) Integration with Nonagon N9+ Device and Virtual Exam Platform – Resident Dashboard – Clinical Tab

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PointClickCare (PCC) Integration with Nonagon N9+ Device and Virtual Exam Platform – Resident Dashboard – Admin – Misc Tab

Dr. M. Rosen — Thu, 31 Aug 2023 18:13:24 +0000

PointClickCare (PCC) Integration with Nonagon N9+ Device and Virtual Exam Platform – Resident Dashboard – Admin – Misc Tab

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PointClickCare (PCC) Integration with Nonagon N9+ Device and Virtual Exam Platform – Patient Card

Dr. M. Rosen — Thu, 31 Aug 2023 18:09:27 +0000

Please Click Patient Card Below:

PointClickCare (PCC) Integration with Nonagon N9+ Device and Virtual Exam Platform – Patient Card

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The ATA Telehealth Essentials Guide for Healthcare Providers

Dr. M. Rosen — Wed, 30 Aug 2023 18:52:40 +0000

Eight Essentials of Effective Telehealth Services, including:

Making the Business Case & Activating an Executive Champion
Making Telehealth Easy for Your Clinicians, Staff & Patients
Understanding Essential Telehealth Policies & Regulations
Moving as Fast as Your Organization’s Culture & Budget Will Allow

The Essentials Guide was made possible thanks to the generous support of the David M.C. Ju Foundation.

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CMS’ Proposed Fee Schedule Boosts Payments for Telehealth

Dr. M. Rosen — Tue, 18 Jul 2023 17:05:29 +0000

CMS proposed changes to the physician fee schedule that would provide physicians with additional compensation to account for balancing telehealth visits with maintaining their physical offices, Politico reported July 17.

The proposal would increase the payment rates of healthcare providers for the virtual care they offer Medicare patients remotely.

The additional compensation for telehealth services will be determined through a “non-facility” payment rate, which will vary based on the type of service being provided, according to the report.

The proposal also seeks to make the following changes, according to the report:

Federally qualified health centers and rural health clinics can bill patients separately for remote patient monitoring.
Physicians are permitted to virtually supervise certain medical services through 2024 that were previously required to be in-person.
The categorization process will be simplified for telehealth service billing.
The pandemic rules that allowed audio-only telehealth visits for certified opioid treatment programs will be maintained through 2024.

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Virtual-first health plans: Faster, affordable care for your employees

Dr. M. Rosen — Tue, 06 Jun 2023 17:07:59 +0000

Over the last several years, Anthem Blue Cross and Blue Shield of Missouri has been expanding access to care through telehealth, urging consumers to use this valuable tool as an entry point to care that is fast, easy and more affordable. In the early days of the pandemic, we worked with our care provider partners to rapidly meet the need for telehealth, which had become immediately necessary. As more of our care provider partners embraced the model of making virtual the first access point to care, health plans accelerated their work in this area.

The health care industry is experiencing a digital revolution that’s making the consumer experience more customized, predictive and proactive. We’re taking the next step by now offering virtual-first health plans. Now is the time for St. Louis employers to take advantage of virtual-first plans to modernize their approach to employee health and health benefits given the central role these play in productivity and talent retention.

What are virtual-first plans?

Virtual-first plans give consumers more affordable access to convenient, quality care options, first. While each plan boasts its own set of unique offerings, virtual plans include access to tools and programs, symptom checkers leveraging artificial intelligence, routine wellness care, chronic condition management, behavioral health care and more. In addition, employers can see savings of up to 20% with Anthem Link, Virtual-First health plans as compared to other traditional health care offerings.

Utilization and demand are increasing

For consumers, virtual-first plans enhance their care by offering easy access to benefits, cost transparency tools and resources they need 24/7. According to one study, convenience and accessibility are among the top traits that people find most appealing about virtual care. The ability to chat with a doctor from wherever they are (35%), 24/7 availability (31%), and the overall ease of use (30%) are also appealing.

Consumers are also looking for more connected care. For example, through the Anthem Blue Cross and Blue Shield digital health platform, we are working to ensure Anthem Link, Virtual-First health plans can connect care data from various visits and care providers throughout the health care system. In many cases, interoperability – or the ability to exchange data – allows care data to move more seamlessly between virtual-first providers, in-person doctors and specialists. This helps enhance the health care experience by reducing redundancies as people go from one care setting to another and, as appropriate, giving providers easier access to previous health information.

Virtual-first plans benefit employers

Employers are looking for the right network options and plan designs to meet their employees’ health goals as well as their business needs. We partner with our customers to build a deep understanding of their population needs, high-cost conditions and local health contexts, so the networks and supporting programs they select will drive results. Virtual-first plans help reduce barriers to care for employees, helping to boost productivity with reduced travel and wait time associated with care, bringing immediate savings to employers.

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