Reimbursement for Virtual Check-ins and e-Visits in the Proposed 2021 Medicare Physician Fee Schedule

On August 3, 2020, the Centers for Medicare & Medicaid Services (“CMS”) released it Proposed Medicare Physician Fee Schedule for CY 2021 (“Proposed MPFS”), seeking to expand reimbursement for Virtual Check-ins and e-Visits as a way of improving access to patient care. CMS proposes seven new HCPCS codes for these “Communication Technology-Based Services” that could be billed by practitioners who cannot bill Evaluation and Management (“E/M”) services independently.

What is a Virtual Check-in under the 2021 Proposed MPFS?

In the 2019 final 2019 Medicare Physician Fee Schedule, CMS created HCPCS Codes G2010 and G2012 to reimburse physicians, nurse practitioners, and physician assistants for time spent evaluating an image sent by a patient or time spent communicating virtually with a patient to determine whether their condition warrants an in-office (or potentially, an equivalent telehealth) visit. If the practitioner determines that no office visit is necessary within 24 hours AND an in-office visit has not occurred within 7 days prior, the virtual interaction is reimbursed. The code descriptors for these virtual communications services are as follows: 

HCPCS G2010 (~ $12): Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment

HCPCS G2012 ($15): Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion

The 2021 Proposed MPFS would extend reimbursement for these virtual communications services to include Qualified Healthcare Professionals who cannot independently report these Evaluation/Management services – including but not limited to clinical psychologists, licensed clinical social workers, physical therapists, occupational therapists, and speech language pathologists. Notably, CMS proposes that the reimbursement amounts for the new codes will be the same as the reimbursement amounts for G2010 and G2012, which are conducted by physicians. The descriptors for the two new proposed codes are as follows: 

HCPCS Code G20X0: Remote assessment of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment

HCPCS Code G20X2: Brief communication technology-based service, e.g. virtual check-in, by a qualified health care professional who cannot report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion)

What is an e-Visit under the 2021 Proposed MPFS?

The 2020 Final Rule finalized six new codes in the category of “e-Visits” providing new opportunities for physician practices to be reimbursed for conducting digital health assessments and evaluations for their patients over the course of 7 days, where the assessment/evaluation is not a result of a visit during the prior 7 days. During the COVID-19 Public Health Emergency, CMS clarified that these e-visits could take place via an online patient portal that allows communication between patient and provider. The 2020 code descriptors were as follows:

HCPCS code G2061 ($12): Qualified nonphysician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the 7 days; 5-10 minutes

HCPCS code G2062 ($22): Qualified nonphysician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 11-20 minutes

HCPCS code G2063 ($34): Qualified nonphysician healthcare professional assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 21 or more minutes

CPT code 99421 ($16): Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes

CPT code 99422 ($31): Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 11-20 minutes 

CPT code 99423 ($50): 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

While it was broadly understood in 2020 that the above CPT codes were for physician services, it was not clear what other types of providers could be reimbursed under the HCPCS codes. In answer to this question, the 2021 Proposed MPFS states that these services could be billed, for example, by licensed clinical social workers and clinical psychologists, as well as physical therapists, occupational therapists, and speech language pathologists who bill Medicare directly for their services “when the service furnished falls within the scope of these practitioner’s benefit categories.” To make clear the distinction, the 2021 Proposed MPFS recommends replacing the 2020 e-visit G codes with new CPT codes, similar to the above CPT codes for physician e-visits. 

CMS refers to the new Virtual Check-ins and e-Visits codes as “sometimes therapy” services. They are appropriate for use with established patients, and the required patient consent may be obtained by auxiliary personnel. In the 2021 Proposed MPFS, CMS requests comments on what other benefits categories may be appropriate for these services. 

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