ACOFP is kicking off a three-part series discussing major proposals in Medicare’s Physician Fee Schedule (PFS) proposed rule and the Hospital Outpatient Prospective Payment System (OPPS) proposed rule. Throughout the series, we intend to highlight major proposals relevant for ACOFP members and encourage individual physicians to submit comments to the Centers for Medicare & Medicaid Services (CMS). In this first blog post, we will discuss the recent telehealth proposals in the PFS proposed rule.

In response to the COVID-19 pandemic, CMS has promulgated regulatory flexibilities for delivering telehealth services to help improve access to care while limiting exposure to the coronavirus for both physicians and patients. This year’s PFS builds on these flexibilities by making permanent or temporarily allowing certain services to be furnished via telehealth to Medicare beneficiaries.

Specifically, CMS proposes to make the following services provided via telehealth permanently reimbursable under Medicare. 

  • Group psychotherapy — CPT code 90853
  • Domiciliary, rest home or custodial care services; established patients — CPT codes 99334–99335
  • Home visits; established patient — CPT codes 99347–99348
  • Cognitive assessment and care planning services — CPT code 9948
  • Visit complexity inherent to certain office/outpatient E/Ms — HCPCS code GPC1X
  • Psychological and neuropsychological testing — CPT code 96121

CMS is proposing to make the following services provided via telehealth reimbursable under Medicare through the year that the COVID-19 public health emergency (PHE) ends.

  • Domiciliary, rest home or custodial care services; established patients — CPT codes 99336–99337
  • Home visits; established patients — CPT codes 99349–99350
  • Emergency department visits, Levels 1–3 — CPT codes 99281–99283
  • Nursing facilities discharge day management — CPT codes 99315–99316
  • Psychological and neuropsychological testing — CPT codes 96130–96133

CMS also is considering additional services to the telehealth list that may be relevant for your practice. For example, CMS is considering allowing physicians to furnish home visits for new patients. This could allow physicians to treat seniors in their homes regardless of whether the physician had seen the patient before the visit. See the full list of telehealth services being considered by CMS.

Since March 31, Medicare has provided payments for audio-only E/M services furnished by family physicians. As part of this proposed rule, CMS is requesting stakeholder feedback on whether the agency should create a unique payment policy for audio-only E/M services. Specifically, CMS is looking for feedback on the resources needed and practice expenses associated with furnishing such services to establish an appropriate payment rate. Furthermore, CMS wants to hear from physicians as to whether this policy should be expanded beyond the COVID-19 PHE. We understand that many ACOFP members have been utilizing this flexibility and encourage members to submit comments to CMS.  

There also are proposed telehealth-related policies affecting remote patient monitoring and direct supervision using telecommunications technology. For example, CMS is clarifying that only physicians and nurse practitioners may furnish remote monitoring services. The proposed rule also would allow physicians in the office setting to meet the definition of “direct supervision” when the physician is available through real time, interactive audio and video technology. This would be available through December 31, 2021. CMS is asking health care stakeholders to provide comment on these proposals.

The proposed rule reflects CMS’s recognition that telehealth is an important tool for physicians, but CMS needs to hear from family medicine physicians about the importance of telehealth. As small practices are struggling to provide access to patients and keep their practices open during the COVID-19 PHE, it is more important than ever for physicians to weigh in on telehealth policies. CMS needs to hear from family medicine physicians about what is working and what is not and how telehealth is helping to keep practices open during the pandemic. This type of feedback can help CMS craft policies that meet the needs of family medicine physicians.  

We understand the rule is lengthy and time-consuming to read, so ACOFP has prepared a comprehensive summary detailing the major proposals under the PFS. The summary captures what you need to know for the telehealth proposals as well as other policies in the rule.  ACOFP will be submitting comments on the proposed rule to promote member priorities, but we encourage individual physicians to submit comments as well.

Submit your comments to the Physician Fee Schedule (PFS) proposed rule by October 5, 2020.

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