As part of the October 31, 2014 final rule updating payment polices under the Medicare physician fee schedule, CMS continued its policy of allowing payment for non-face-to-face chronic care management services and also expanded the list of Medicare-covered telehealth services. However, CMS declined to provide coverage for other proposed telehealth services, and the agency noted the limits of its authority to expand Medicare support for telehealth under current law.
The final rule implements a recently announced policy to reimburse physicians for the time they spend performing non-face-to-face chronic care management (CCM) services for patients with multiple chronic conditions. CMS introduced the policy to address concerns that existing reimbursement codes did not sufficiently compensate doctors treating patients with multiple conditions. While CCM services are not telehealth services per se, coverage of such services suggests that CMS is becoming more comfortable paying providers for non-face-to-face care. In this year’s final rule, CMS also indicated that it will consider whether additional CCM reimbursement is warranted for remote monitoring of patient data.
CMS also added seven new telehealth services as part of its annual process for updating the list of covered Medicare telehealth services. Each year, the agency evaluates public requests to add services based on whether the services are similar to those already covered or whether their provision via telehealth shows clinical benefit to patients. The newly covered services in this year’s rule include psychotherapy services, prolonged service office visits, and annual wellness visits. All were added based on their similarity to already-listed procedures.
Despite expanding the list of telehealth services, CMS declined to add other services to the list and also noted the limits of its authority to broaden Medicare telehealth coverage more generally.
The agency concluded that it would be “inappropriate” to reimburse services such as the collection or analysis of digitally stored clinical data (e.g., electrocardiogram (ECG), blood pressure, or glucose monitoring data) when provided via telehealth because such services are not otherwise separately payable by Medicare. CMS also declined to list certain services that include a “technical component” which “[b]y definition . . . needs to be furnished in the same location as the patient . . . .” However, CMS noted that reimbursement for the “professional component” of such services is already available regardless of whether the service is provided via telehealth. For example, although a routine ECG with interpretation cannot be reimbursed as a telehealth service, physicians may already bill for the interpretation of an ECG regardless of whether the patient is present. CMS similarly declined to provide separate reimbursement for psychological testing administered by a computer and interpreted by a health care provider because this is already reimbursable regardless of whether the patient is present. Finally, the agency declined to add services for which public requestors did not submit evidence showing the clinical benefit of telehealth provision.
In responding to comments recommending broader changes to Medicare telehealth policy, CMS noted the limitations of its current authority. Commenters proposed changes such as allowing reimbursement in urban areas, designating patients’ homes and other locations as permissible “originating sites,” and adopting a broader definition of telehealth technologies to include services provided via mobile technology. CMS did not respond directly to each comment but stated that it lacks authority to implement many of the revisions under current law. CMS noted that the CMS Innovation Center, which is responsible for developing and testing new payment and delivery models, may test changes to Medicare telehealth payment policies.