In March, CMS and other Federal agencies announced temporary telehealth policy changes in response to the COVID-19 public health emergency. These changes promoted continued access to care while allowing for physical distancing. Virtual care encounters have increased since March. However, as the public health emergency has continued, there are questions about the future of virtual care.
In early August, CMS released a fact sheet with proposals and clarifications to their virtual care policies for the CY 2021 Physician Fee Schedule.
Telehealth Services Codes
CMS proposed 9 Medicare Telehealth services for permanent adoption and 13 to maintain through the remainder of the public health emergency. However, CMS has not clarified whether telehealth can be used to establish a patient/provider relationship – now a crucial step in providing Remote Patient Monitoring services. Remote Patient Monitoring is the use of technology to monitor patient physiologic data from outside the clinic. This includes things like blood pressure and blood glucose. CMS also proposed two new codes to allow non-physician practitioners to furnish virtual check-ins, short status checks that do not take place in person. These practitioners include clinical social workers, clinical psychologists, physical therapists, occupational therapists, and speech-language pathologists.
Remote Patient Monitoring Services
The fact sheet presented 3 key updates to the Remote Patient Monitoring policy:
- After the public health emergency, CMS will only cover Remote Patient Monitoring for established patients. During the public health emergency, they had expanded coverage to include both new and established patients.
- CMS clarified that Remote Patient Monitoring treatment management services (CPT Codes 99457 and 99458) can only be fulfilled through 20 minutes of synchronous patient interactions, not including time spent collecting and analyzing Remote Patient Monitoring data.
- CMS maintained that providers cannot bill Remote Patient Monitoring initial set up and education services (CPT 99453 and 99454) more than once per patient every 30 days, regardless of how many devices the patient uses.
These changes may disincentivize clinicians from providing virtual care beyond the public health emergency. If a patient requires both a blood glucose monitor for diabetes and blood pressure monitor for hypertension, their provider will only be covered for the time spent setting up one of these devices – not both. The provider may choose to delay one of the devices until the next billing cycle, putting the patient at risk.
Stakeholder Perspectives on the Future of Virtual Care
The Taskforce for Telehealth Policy convened earlier this summer to build consensus among diverse healthcare stakeholders and provide policy recommendations. The group – consisting of industry experts representing clinicians, health systems, telehealth platforms, state and federal health agencies, insurers, and consumer advocates – recently released a report with their recommendations. They explicitly recommend policymakers acknowledge that telehealth visits generally meet requirements for establishing a clinician/patient relationship. They also recommend permanent adoption of other temporary virtual care policies, such as:
- Lifting geographic restrictions and limitations on originating sites.
- Allowing telehealth for various types of clinicians and conditions.
- Lifting restrictions on telehealth across state lines.
The recommendations in the report arise from stakeholders with multiple perspectives who serve a diverse population. The previous CMS guidance is specific to Medicare beneficiaries. Thus, there are some differences in focus between the report and CMS FAQs
CMS solicited public comments through the end of September to inform the final rule that will result in telehealth policy changes. We will continue to monitor and share updates.
Saira Haque
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