Virtual Check-Ins, Remote Evaluation of Images, Chronic Care Remote Monitoring, and more

With the July 12, 2018 release of its proposed Medicare Physician Fee Schedule for 2019, CMS further opened the door for use and reimbursement of Remote Patient Monitoring (or Remote Physiologic Monitoring, "RPM") services. In doing so, CMS recognizes the role that new communications technologies play in increasing patient engagement and reducing unnecessary costs.

Medical practices and healthcare technology companies providing RPM services, take note: Comments requested! 

CMS is requesting comments on the specifics of its proposal by September 10, 2018. Now is the time to make your voice heard. Please contact us if you would like assistance in drafting and submitting your comments to CMS. 

What's the difference between "Medicare Telehealth Services" and "Remote Patient Monitoring Services" - and why does it matter?

CMS's Proposed Rule articulates for the first time a firm distinction between "Medicare telehealth services" as defined by law with its specific originating site and geographic restrictions, and RPM services that are not subject to these same restrictions. "We have come to believe that section 1834(m) of the Act [establishing Medicare Telehealth services] does not apply to all kinds of physicians’ services whereby a medical professional interacts with a patient via remote communication technology," states CMS. "Instead, we believe that section 1834(m) of the Act applies to a discrete set of physicians’ services that ordinarily involve, and are defined, coded,  and paid for as if they were furnished during an in-person encounter between a patient and a health care professional" (emphasis added). RPM services, on the other hand, are "services that are defined by and inherently involve the use of communication technology," but would not otherwise be furnished during an in-person visit. 

In an effort to increase patient access to technology-based communication, CMS proposes "modernizing Medicare physician payment for communication technology-based services," making them separately payable to practices who utilize them as part of patient care. Below is a summary of newly proposed reimbursable services.

"Virtual Check-ins" - Brief Communication Technology-based service (HCPCS Code GVCI1)

With this newly proposed code, CMS recognizes that advances in technology have changed the quality and quantity of information that can be conveyed remotely by patients to their healthcare providers. Whereas previously, a patient would have to schedule an in-person visit in order to check in with his or her physician regarding a health concern, that same patient and physician can now use a technology platform for a brief five to ten minute virtual consult to determine whether a face-to-face visit is warranted - thereby reducing the number of unnecessary office visits. This check-in would be reimbursable as a standalone service if it does NOT occur within 7 days of a prior E/M service by the same provider AND it does NOT lead to an in-person E/M service within the next 24 hours. If an in-person visit results within 24 hours, reimbursement for the check-in is considered bundled into the E/M service. Under the Proposed Rule, the check-in would be initiated by the patient, and the patient would be responsible for the standard Medicare co-pay.  

CMS is specifically seeking comment from stakeholders on the following:

  • What types of technology may be used for Virtual Check-ins? Are these technologies demonstrably better than audio-only telephone calls, and if so, why?
  • Should patient consent be required for Virtual Check-ins? If so, what type?
  • Should reimbursement for Virtual Check-ins be limited in frequency? 
  • What are the timeframes for which Virtual Check-ins should be separately reimbursable versus bundled with an E/M service?
  • How should clinicians document medical necessity of a Virtual Check-in?
  • What is the appropriate definition and valuation of this code?

Remote Evaluation of Pre-recorded Patient Information (HCPCS Code GRAS1)

This new code involves use of "Store-and-Forward" technology that allows asynchronous (as opposed to real-time) transmission by the patient of still or video images. Under the code, healthcare professionals would be reimbursed for evaluation of these images to assess a patient's condition and determine whether an in-person office visit is warranted. When the evaluation does result in an in-office visit, CMS suggests that reimbursement for the service would be bundled into the E/M service reimbursement. However, similar to the Virtual Check-in, if an in-office visit does NOT result, and the remote evaluation does NOT occur within 7 days of a prior E/M service by the same healthcare professional, the service would be reimbursed as a standalone service. 

CMS is specifically seeking comment from stakeholders on the following:

  • Should this service be limited to established patients, or are there circumstances where it would be appropriate for new patients (e.g. in a dermatology setting)?
  • What is the appropriate definition and valuation of this code?

Interprofessional Internet Consultations (CPT codes 994X6, 994X0, 99446, 99447, 99448, and 99449)

In recognition of the potential benefits to a patient of consultation with another healthcare professional, CMS proposes making separate payments for these consultations when conducted by telephone, internet, or electronic health record referral services. CMS proposes requiring advance beneficiary consent to such consultations, documented in the patient record.

Chronic Care Remote Physiologic Monitoring (CPT codes 990X0, 990X1, and 994X9)

CMS originally received requests to add these codes to the list of existing Medicare Telehealth Services. However, CMS deemed that these services should actually be classified as remote monitoring services, and therefore not subject to Medicare's restrictions on telehealth services. CMS proposes to make these codes - used to remotely monitor physiologic parameters such as weight, blood pressure, pulse oximetry, and respiratory flow rate in patients with two or more chronic conditions - separately reimbursable. Notably, as distinct from CPT Code 99091 for Remote Patient Monitoring that was unbundled for standalone reimbursement in the 2018 Medicare Physician Fee Schedule, these codes may be billed by a Qualified Health Care Professional OR by clinical staff. 

  • CPT Code 990X0: initial set-up and patient education on use of equipment
  • CPT Code 990X1: initial device supply with daily recordings or programmed alerts, 30 days
  • CPT Code 994X9: 20 minutes or more of clinical staff/physician/other qualified healthcare professional time in a calendar month requiring interactive communication with the patient/caregiver during the month

Your feedback to CMS on these proposals is important for continued progress in making healthcare technology innovations accessible to patients. Please don't hesitate to contact us for assistance in drafting formal comments for submission to CMS.