CMS is trying to kick off the New Year right – at least when it comes to telemedicine. Beginning January 1, 2019, the Centers for Medicare & Medicaid Services (CMS) published their “Revisions to Payment Policies under the Medicare Physicians Fee Schedule, Quality Payment Program and Other Revisions to Part B for CY 2019.” These reimbursement revisions made changes to remote patient monitoring and originating site requirements that removed some of the barriers to telehealth. But these clarifying rulings also created a new “virtual check-in” code, HCPCS G2012, to help providers determine whether the patient needs an office visit or a telehealth call. Health Law Informer says, “ To the extent the in-person visits are rendered unnecessary by the “virtual check-in,” both CMS and the patient save money.”
Here are some of the facts surrounding Medicare’s virtual check-in codes.
This new rule came about as a change to the Medicare physician fee schedule and other Medicare Part B payment policies. It’s a very exciting policy change, signaling that CMS is finally starting to recognize the value in telehealth services.
CMS defines the virtual check-in as a “brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified healthcare professional that can report EM (evaluation or management) services.” Typically, these calls are just five to 10 minutes long.
Traditionally under CMS, brief telephone calls were non-billable and part of the in-office visit. Just ask any on-call doctor how convenient that middle of the night phone calls is and you’ll understand why these calls should have been reimbursable. Now, with the new CMS rule revision, these calls by audio or video can be part of the virtual check-in reimbursement code. Some of the rule stipulations include:
- The code is only available for the established patient. If you’re wondering what constitutes an established patient, look at the CPT definition:
One who has received professional services from the physician or qualified health care professional or another physician or qualified health care professional of the exact same specialty and subspecialty who belongs to the same group practice, within the past 3 years.
- The “virtual” part of the virtual visit includes telephone interactions, as well as synchronous (two-way) audio or video interactions.
- Reimbursement is unfortunately not offered for store-and-forward or asynchronous virtual visits.
- Email, text, or voicemail are not reimbursable under this code.
- For reimbursement to occur, the virtual check-in code must not relate to an E/M provided to the patient in the past seven days.
- Code HCPCS G2012 also cannot be used if the patient winds up seeking treatment in the 24-hours following the call.
- Only the billing clinician (i.e. physician or another qualified healthcare provider) under E/M can use this code.
- The virtual check-in must be “reasonable and necessary.”
- As a Medicare Part B service, there is a co-pay under the CMS code.
- There are no frequency limits to this code. That makes it particularly effective for behavioral health treatments including assessments of risk of suicide or medication check-ins. While Healthcare Law today says that CMS will monitor the code for overuse, “Even without an express frequency limitation, virtual check-ins, like all other physicians’ services billed under Medicare, must be medically reasonable and necessary to be reimbursed.”
- The patient must give verbal consent for the virtual check-in and it must be documented in their chart. This is due, in part, to the patient co-pay requirement. Written consent is not a requirement. It should be noted that the patient must give consent for each virtual visit, not just once. Healthcare Law Today points out:
This is a disappointing requirement for the patient’s user experience, particularly as CMS could have allowed a process where the patient gave consent once, and the practitioner kept a copy on file.
- Health Law Informer says the typical reimbursement will be around $14 for the virtual check-in.
While there are no restrictions related to the frequency of using this code, CMS kept annoying timeframe restrictions, including the “soonest available appointment” clause. Specifically, CMS said:
If the virtual check-in leads to another E/M service with the same physician or another qualified healthcare provider within the next 24-hours or soonest available appointment, it would not be separately billable.
Healthcare Law Today says:
It might be challenging to prove whether or not other appointments were available prior to the visit, especially since beneficiary convenience is also presumably a factor for when appointments are scheduled.
It is also worth noting that CMS discarded their idea of originating sites under this new rule. Patients can receive this virtual visit and doctors can provide it from any location. That is a huge step in the right direction for telehealth advocates. But what are healthcare pundits saying about the new virtual CMS code and what it means for the future of telemedicine?
“The decision to expand reimbursement for providers for the use of communication technology-based services recognizes the important role these services play in increasing patient engagement and reducing unnecessary costs. These policy updates signal that CMS is moving quickly to incentivize the integration of innovative technologies as it pushes for the transition to value-based care.”
Even CMS acknowledges that the new virtual visit code will help cut down on unnecessary office or ER visits. One CMS administrator was quoted as saying:
Many times this type of check-in will resolve patient concerns in a convenient manner that gets them the care that they need and avoids unnecessary cost to the system. This is a big issue for our elderly and disabled populations where transportation can be a burden to care as well as to caregivers. We’re not intending to replace office visits but rather to augment them and provide new access points for patients.
The new CMS codes, while a step in the right direction, do still have some limitations that could thwart widespread adoption. Getting paid to provide care in a virtual setting gives doctors an incentive to continue to push toward lowered costs by eliminating unnecessary on-site visits. Patients can now upload images or engage with doctors by sharing a video of their ailments, which is a big step in the right direction. These changes can help cut costs and improve patient access to care.
OrthoLive can help your practice add a billable virtual visit to the mix of services you offer patients. Contact us today.