Last night, CMS released the CY2019 Physicians’ Fee Schedule and the CY 2019 ESRD payment update. The PFS contains a number of provisions reflecting the administrations priorities including expanded access to telehealth services and paperwork reduction.
Telemedicine. CMS has decided that they can reinterpret current law to permit reimbursement of new categories of reimbursement in the Medicare program. Those are:
- Brief Communication Technology-based Service e.g. Virtual Check-in (HCPCS: GVCI1). Effective Jan. 1, 2019, CMS will permit physicians to submit for reimbursement of virtual visits that are designed to assess whether an office visit is necessary. If an office visits results, then payment will be bundled. If an office visit does not result the virtual visit will be separately payable. The service would only be available to established patients.
- Remote Evaluation of pre-recorded Patient Information (GRAS1). Effective Jan. 1, 2019, CMS would permit reimbursement for remote professional evaluation of patient-transmitted store and forward video or image technology. In this case, CMS will not require the patient have an established relationship with the physician.
The first of the new services will benefit white label solutions like American Well and SnapMD. The second seems designed for Teladoc which does a brisk business in assessing dermatological incidents.
The rule is, as expected, unbundling Inter-professional Internet Consultation (CPT 994X6, 994X0), 99446, 99447, 99448 and 99449) from a patient encounter to allow them to be separately billable but not without some angst. The rule makes it clear that Medicare does not want to pay for continuing education so it is seeking comment on how it can limit the definition of Inter-professional Internet Consolation.
Finally, CMS is implementing provision of the Bi-Partisan Budget Act of 2018 that expands telehealth services to stroke patients and ESRD beneficiaries.
Laboratories. In response to industry concerns, CMS is revising the definition of “applicable laboratory.” Currently, any lab that receives more than 50 percent of revenues from Medicare must submit commercial claims data to CMS for calculating PAMA rates. Medicare is defined as Medicare FFS and Medicare Advantage. CMS is proposing that Medicare Advantage payments be excluded from the 50 percent threshold criteria.
The purpose of the change is to require more laboratories – specifically hospital-based – to report their commercial payment data. This change is a big win for the industry.
Hospital Outpatient Department. CMS is proposing to retain the 40 percent payment reduction for new off-campus hospital outpatient departments. The industry was hoping to roll this reduction back but were unsuccessful. In fact, CMS reiterated its view that Congress’s intent is a site neutral payment system and their objective, as data becomes available, is to execute.
Outpatient Dialysis. CMS is proposing a 1.5 percent increase in the base payment.
The payment change should result in about $220 million increase in outlays to dialysis providers.
Call with question. The above represents 2000 pages of the Federal Register so I am sure you have some.
Emily Evans
Managing Director
Health Policy
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