Recently, the Centers for Medicare and Medicaid Services (CMS) released a proposal for the 2019 Physician fee schedule. CMS’s rule includes recommendations that foster innovation through the use of communication technology.
New Codes for Communication Technology
The part of the rule that is relevant for the telemedicine industry is the proposed addition of two codes:
- Brief Communication Technology-based Services (HCPCS code GVCI1), and
- Remote Evaluation of Recorded Video and/or Images Submitted by the Patient (HCPCS code GRAS1).
HCPCS code GVCI1 would allow physicians to get reimbursed for quick video visits, including encounters to determine whether an office visit is necessary or additional treatment is required. HCPCS code GRAS1 would, “Allow practitioners to be separately paid for reviewing patient-transmitted photo or video information conducted via pre-recorded ‘store and forward’ video or image technology to assess whether a visit is needed.”
Both codes are intended to be used with communication technology. CMS’s decision to include these codes in the proposal is a big win for telemedicine because it validates the use of communication technology. The CMS fact-sheet contains additional code details.
The addition of these services is excellent news for patients because it would increase access to healthcare. Additionally, this proposed change would be beneficial for providers because it would open a new channel of communication to allow providers to more efficiently connect with patients, which would result in cost savings, improved efficiency, and better health outcomes. Moreover, the addition of these codes would mean that providers would be eligible for the reimbursement of services they may already provide without compensation.
Streamlined E/M Billing
The proposal also includes an overhaul of the documentation requirements for Evaluation and Management (E/M) billing. Currently, providers use a combination of time, history, physical examination, and medical decision making to determine the level of a visit. The new guidelines would, “Allow practitioners to choose to document office/outpatient E/M visits using medical decision-making or time instead of applying the current 1995 or 1997 E/M documentation guidelines.” Under the new rule, it would be appropriate to use time as the governing factor in selecting visit level and documenting the E/M visit, regardless of whether counseling or care coordination dominate the visit.
The new guidelines would encourage practitioners to, “Focus more on what has changed since the last visit or on pertinent items that have not changed, rather than re-documenting information, provided they review and update the previous information.”
The proposal to overhaul E/M documentation is important to the telemedicine industry because a number of private payers currently reimburse for E/M services provided via telemedicine. As we know, most private payers follow Medicare guidelines. As a result, we can expect private payers to adopt this rule, which would result in more efficient documentation for telemedicine.
It is clear from the proposal that CMS recognizes the growing importance of health technologies, including telemedicine in the nation’s approach to healthcare delivery. While CMS hasn’t yet reached the level of parity between telehealth and in-office visits that many states require of private payers, this proposed rule change is an important step on the path to a more modern payment structure.