The Centers for Medicare & Medicaid Services issued the final physician fee schedule for 2021 yesterday.
The 2,165-page final rule covers several updates, including a new physician fee schedule conversion factor of $32.41 for next year, down from $36.09 in 2020.
Key among its updates are additions to the list of telehealth services covered under Medicare, new payment policies for some remote physiologic monitoring services and a revised definition for direct supervision by telecommunications technology.
Here are five important takeaways related to telehealth and technology-enabled care:
1. CMS added services to its telehealth coverage list. The physician fee schedule final rule adds more than 60 services to the Medicare telehealth list, which means they will be covered even after the Covid-19 pandemic has ended. When the Covid-19 crisis began, CMS added 144 telehealth services — including emergency department visits and discharge day management services — to its coverage list through the end of the public health emergency. Early data shows that Medicare telehealth services are being widely used. Between mid-March and mid-October, over 24.5 million beneficiaries and enrollees received care via telemedicine.
So, CMS created a new category of criteria for adding to its list of covered telehealth services during the public health emergency that will remain there after the crisis has ended. Added services also include continuing neonatal intensive care services and physical and occupational therapy services.
2. CMS changed limitations on nursing facility telehealth visits. Medicare previously covered only one telehealth visit per month for beneficiaries in nursing facilities. But stakeholders argued that this frequency limitation “provides unnecessary burden and limits access to care for Medicare beneficiaries in this setting.” CMS has updated the limitation to one telehealth visit every 14 days.
3. CMS expanded the pool of practitioners who can bill for telehealth services. Per the final rule, licensed clinical social workers, clinical psychologists, physical therapists, occupational therapists and speech-language pathologists can provide short online assessment and management services as well as virtual check-ins and remote evaluation services. CMS created two new Healthcare Common Procedural Coding System codes to allow these practitioners to bill for the services.
4. CMS clarified payment policies for some remote physiologic monitoring services. Specifically, CMS updated payment policies related to the remote physiologic monitoring services described by CPT codes 99453, 99454, 99091, 99457 and 99458. For example, to meet the requirements to bill CPT codes 99453 and 99454, 16 days of data each 30 days of remote monitoring must be collected and submitted.
In addition, the final rule states that to provide remote physiologic monitoring services after the Covid-19 public health emergency ends, there must be an established patient-physician relationship.
5. CMS revised the definition of direct supervision by interactive telecommunications technology. CMS has adopted an interim final policy that updates the definition of direct supervision to include “the virtual presence of the supervising physician or practitioner using interactive audio/video real-time communications technology.” Direct supervision may be conducted virtually through at least Dec. 31, 2021.
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