HHS released an updated interim final rule on March 30 that will reimburse nephrologists and physician practice staff for all telehealth visits for patients in dialysis clinics and at home. Visits with patients via telephone are also now reimbursed, with payment based on the length of the call.
“Most pertinent for nephrology, the [interim final rule] IFR clarifies that all physician and practitioner activities associated with the ESRD MCP outpatient dialysis services can be provided via telehealth,” the Renal Physicians Association told its members in a guidance letter about the rule. “Subsequent to the release of the March 17 guidance, there were differing interpretations as to whether the complete assessments associated with the MCP still needed to be provided face-to-face; the IFR adds all outpatient dialysis services to the list of services that now can be fully provided via telehealth means.”
CMS updated the interim final rule after President Donald J. Trump signed the 2020 CARES Act on March 27 that included financial aid to physician practices and waived face-to-face requirements for home dialysis monthly services.
“ … Given the exposure risks for beneficiaries, the health care work force, and the community at large, in-person interaction between professionals and patients poses an immediate potential risk that would not have been present when we previously reviewed these services,” HHS said in the updated rule. “ … We note that the risks to medical professionals treating patients is high and we consider it likely that medical professionals will try to treat patients as effectively as possible without exposing themselves or their patients unnecessarily.”
“In some cases, use of telecommunication technology could mitigate the exposure risk, and in such cases, there is a clear clinical benefit of using such technology in furnishing the service,” HHS said.
With recent approval of payment for short “check-ins” with patients and use of telephones to provide consults, the agency said often times such physician-patient interactions are adequate to understand a patient’s health. “In the context of the [public health emergency] PHE for the COVID-19 pandemic, when brief communications with practitioners and other non-face-to-face services might mitigate the need for an in-person visit that could represent an exposure risk for vulnerable patients, we believe that these services should be available to as large a population of Medicare beneficiaries as possible,” HHS said.
The CARES Act also allows Medicare prescription drug plans to provide 90-day refills of covered Medicare Part D drugs, including immunosuppressive drugs for kidney transplant patients.
Nephrology practices billing for Medicare telehealth services within the MCP will use the same CPT code that would have been reported had the service been furnished in person, according to the revised rule – a change from use of a special code for telehealth services only.
In the IFR, HHS waived the requirement that a nephrologist or practice staff must inspect a patient’s vascular access site in a face-to-face visit.
“For the duration of the PHE, this requirement has been lifted as well, and as with the additions to the telehealth list, this revision applies to all outpatient dialysis services, CPT codes 90951-90970,” the RPA guidance letter said.
Other services that can now be done and billed via telehealth, based on the IFR, include emergency department visits; initial hospital care and discharge day management; initial nursing facility and discharge day management; critical care services, and home visits for new and established patients.
The audio-only telephone consults apply to qualified non-physician health care professionals, such as nurse practitioners and physician assistants, as well as for physicians, the RPA wrote. Payment varies from $14.43 for a 5-minute to a 10-minute call to $41.14 for a 21-minute to a 30-minute call.