Telehealth services are becoming more mainstream and the Centers for Medicare & Medicaid Services (CMS) shows its continued support for remote services in the 2014 Medicare Physician Fee Schedule (MPFS) final rule, published in the Nov. 27 Federal Register.
Prior to 1999, Medicare coverage for services furnished by a telecommunications system was limited to things like X-ray interpretations, electroencephalogram tracing, and cardiac pacemaker analysis. The Medicare, Medicaid and SCHIP Benefits Improvement Protection Act of 2000 (BIPA) significantly expanded Medicare coverage for telehealth services. For example, one provision expanded the Social Security Act to require the Department of Health & Human Services (HHS) secretary to establish a process that provides for annual updates to the list of telehealth services. CMS established this policy in the 2003 MPFS final rule.
Medicare also provides payment of a facility fee to the originating site. Telehealth originating sites are those located in a designated rural health professional shortage area (HPSA) in a county that isn’t in a metropolitan statistical area (MSA), or an entity that participates in an approved federal telemedicine demonstration project.
The initial list of telehealth originating sites included the physician office, critical access hospitals, rural health clinics, federally qualified health centers, and hospitals. The Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) expanded the list to include hospital-based renal dialysis centers, skilled nursing facilities, and community mental health centers.
In the 2014 MPFS final rule, CMS redefines rural HPSAs as those located in rural census tracts as determined by the Office of Rural Health Policy (ORHP), defining “rural” to include geographic areas located in rural census tracts within MSAs. CMS also finalizes its proposal to establish and maintain geographic eligibility for an originating site on an annual basis.
The telehealth originating site facility fee in 2014 is increased by the 2014 MEI increase of 0.8 percent, making the 2014 payment amount for HCPCS Level II code Q3014 Telehealth originating site facility fee 80 percent of the lesser of the actual charge, or $24.63up 20 cents from 2013.
CMS has also greatly added to the list of approved telehealth services over the years. The 2014 MPFS final rule further expands the list of approved telehealth services by adding “transitional care management.”
CMS finalized a payment policy for CPT® transitional care management codes 99495 and 99496 in the 2013 MPFS final rule. These services are for a patient whose medical and/or psychosocial problems require moderate or high complexity medical decision-making during transitions in care from an inpatient hospital setting. Transitional care management is comprised of one face-to-face visit within the specified time frames following a discharge, in combination with non-face-to-face services that may be performed by the physician or other qualified healthcare professional and/or licensed clinical staff under his/her direction.
Continue to append modifier GT Interactive audio and video telecommunications systems or GQ Asynchronous telecommunications system to the procedure code to receive payment equal to the amount the physician would have been paid if the service had been furnished without the use of a telecommunications system.
CMS is soliciting public requests to add services to the list of Medicare telehealth services. The deadline to submit requests is Dec. 31 to be considered for the next rulemaking cycle. For instructions on how to submit a request, go to www.cms.gov/telehealth.