The Centers for Medicare & Medicaid Services (CMS) issued regulatory guidance only 24 hours after our webinar, How to "See" Patients During a Pandemic and Get Paid for It, resulting in more changes to telemedicine reimbursement for Medicare. Although these changes are specific to Medicare, the announcement may prompt other payers to make further changes as Medicare reimbursement policy is a bellwether for our industry. Here is a list of the key points in the guidance related to medical practices:
- Hospital-based outpatient clinics can bill the originating site facility fee for telemedicine services.
- Audio-only codes for physicians and APPs* (99441-99443) receive payment commiserate with E/M codes 99212-4; this new payment rate is retroactive to March 1; the codes are now listed as telemedicine services.
- Advanced practice providers can order, furnish diagnostic tests.
- E/M times defer to the AMA's CPT® definition, instead of those (different) times published subsequently by CMS.
- Remote patient monitoring codes can be billed for services provided for 2+ days.
- Physical and occupational therapists can render payable services via telemedicine.+
Note that the 279-page ruling has changes to many other areas of reimbursement, to include additions to the Primary Care Exception codes, expansion of services that can be rendered at a patient's home, and more.
Most importantly, check out the newly updated telemedicine code list as it now includes a column for services that can be rendered and billed based on audio only; see “Can Audio-only Interaction Meet the Requirements?”
Thanks, to those who attended the webinar. Responses to all webinar questions can be found here. Also, the coding and reimbursement during the COVID-19 pandemic sheet was updated to reflect the changes on April 30. You can find the new document here.
*The CPT® definition is anyone who has evaluation and management in their scope of practice ("who may report E/M..."); it is recognized that there are some varying interpretations of this by payers, however, advanced practice providers (APPs) such as NPs and PAs would be able to bill these codes based on the CPT® definition so they are included herein.
+ See: https://www.cms.gov/files/document/covid-19-physicians-and-practitioners.pdf (updated 4/29/20)