Despite telehealth’s significant expansion over the past ten years, it has been plagued by a historically unstable regulatory and reimbursement landscape. While the reimbursement environment may still have room for improvement, the Centers for Medicare & Medicaid Services (CMS) Medicare physician fee schedule (PFS) Final Rule for CY 2018 (Final Rule) marked some significant victories for those advocating for a more comprehensive reimbursement regime and for telehealth investors.
Beginning in CY 2018, CMS has both: (1) expanded the list of telehealth services that are reimbursed as “Medicare services”; and (2) decreased the burdens for physicians in billing the government for telehealth services.
Additional “Medicare services”
“Medicare services” are defined by the Social Security Act (“Act”) to include professional consultations, office visits, office psychiatry services, and any additional service specified by the Secretary, when furnished via a telecommunications system. When the statutory provision was first implemented, CMS established a process for annual updates to the list of Medicare telehealth services as required by the Act. The process provides the public with an ongoing opportunity to submit requests for adding services, which are then reviewed by CMS.
CMS received many requests in CY 2016 to add various services as Medicare telehealth services effective for CY 2018. Of those requests, CMS determined that seven services should be added as “Medicare telehealth services,” including various psychotherapy services, counseling services, interactive complexity, administration of health risk assessments, and assessments for patients requiring chronic care management services.
CMS’s decision to add seven new categories of services is encouraging for those hoping to see increased reimbursement for telehealth services before entering the market.
Lower Burden on Physician Billing
In addition to adding the services discussed above to the list of Medicare services, CMS also finalized its proposal to eliminate the required reporting of the telehealth modifier GT for professional claims in an effort to reduce the administrative burden for practitioners. Prior to the Final Rule, distant site practitioners were required to report one of two longstanding HCPCS modifiers when reporting telehealth services using the appropriate CPT or HCPCS code for the professional service along with the telehealth modifier GT (via interactive audio and video telecommunications systems). Effective January 1, 2017, CMS also requires a place of service (POS) code describing services furnished via telehealth. CMS determined that the GT modifier was redundant given the POS code and therefore eliminated the requirement thus lessening the burden on practitioners rendering telehealth services.
Of course, proponents of wider telehealth reimbursement and decreased regulations would argue that there is still a long way to go, but these advances improve the reimbursement landscape and should help ease concerns of those interested in telehealth but hesitant to invest given the historical reimbursement issues.