– Last week’s release of The Centers for Medicare & Medicaid Services’ 2019 Physician Fee Schedule and Quality Payment Program offered good news for providers looking to implement telemedicine for virtual check-ins.
While much of the attention was focused on expanded reimbursement for remote patient monitoring services, an overlooked section of the 2,378-page document detailed Medicare coverage for “Brief Communication Technology-Based Service” (HCPCS code G2012). Simply put, this new code gives providers an opportunity to use telehealth to check in with their patients at certain times on care management issues.
“The new code represents a sizeable change to allow providers to efficiently use new technologies to deliver medical care,” says Nathaniel Lacktman, a partner and healthcare lawyer with Foley & Lardner who chairs the firm’s Telemedicine Industry Team and co-chairs its Digital Health Work Group. “By reimbursing for virtual check-ins, the new code exemplifies CMS’ renewed vision and desire to bring the Medicare program into the future of clinically-valid virtual care services.”
The new code, scaled down considerably from what CMS had proposed in July, enables a provider to use “audio-only real-time telephone interactions in addition to synchronous, two-way audio interactions that are enhanced with video or other kinds of data transmission” to check in with an established patient on a care plan.
The CMS proposal for virtual check-ins drew flak from a number of organizations, including the Medicare Payment Advisory Commission (MedPAC), and was the subject of a critical article in Kaiser Health News. According to the Center for Connected Health Policy, some physicians worried that the check-in, which includes a patient co-pay, could lead to over-use and poor provider adoption.
According to the CCHP, some physicians “expressed concern that patients will be reluctant to use check-in calls due to the cost-sharing. Many physicians and hospitals say that they already provide this service for free and reimbursing for it will actually hinder patient access while increasing Medicare spending. CMS Administrator Seema Verma and other CMS officials have stated that the service will save Medicare money by reducing unnecessary office visits and treating health problems before they become a burden to the Medicare system.”
Whether the final, pared-down version of the service meets those concerns remains to be seen.
Lacktman, who wrote a blog about the new code, says the new service should help providers who want to check in with their patients to make sure a care plan is being followed at home. It may prove especially helpful, he says, for behavioral healthcare providers who might need to check on patients with mental health issues.
The new service does have its challenges. According to Lacktman, asynchronous (store-and-forward) technology isn’t allowed, so the provider can’t check in via e-mail or use a survey to determine the patient’s status. Also, the check-in has to be conducted by the physician or a qualified healthcare professional, rather than office staff. And patient consent to use telehealth is required each time the provider connects with the patient.
Lacktman noted there are no frequency limitations to the service, though CMS will be monitoring how it used and could amend that at a later date.
But there are timeframe limitations. The service is described as “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 (E/M) 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).”
Lacktman called the restrictions disappointing, given that these check-ins are often done to improve patient engagement through convenience. He said CMS ultimately decided to keep that language to guard against abuse.
According to Lacktman:
- If the Virtual Check-In originates from a related E/M service provided within the previous seven days by the same physician or other qualified healthcare professional, then the service is considered bundled into that previous E/M service and G2012 would not be separately billable (provider liable). In that event, do not bill either the patient or the Medicare program for that code.
- If the Virtual Check-In leads to an E/M service with the same physician or other qualified health care professional within the next 24 hours or soonest available appointment, then this service is considered bundled into the pre- or post-visit time of the associated E/M service, and therefore, would not be separately billable (provider liable). In that event, do not bill either the patient or the Medicare program for that code.