Intersection of the CMS Proposed Physician PPS “Virtual Interactions” and Proposed Home Health PPS’ “Remote Patient Monitoring”

Physician PPS

CMS’ physician payment proposal would reimburse physicians for certain virtual interactions, a move that some see as a significant first step in overcoming the telehealth payment obstacle. Buried in the 1,473-page proposed rule released last week by CMS are several new proposals to pay physicians for virtual check-ins and reviewing patient photos or videos using asynchronous or “store-and-forward” transmission.

CMS also proposed adding new billing codes for “prolonged preventative services,” along with three new remote monitoring reimbursement codes.

It’s clear CMS is still ironing out the details on the proposal. In its explanation of virtual check-ins, which would include basic telephone calls, CMS asked for industry input about what types of “communication technology” are utilized by physicians, whether or not to include frequency limitations and how physicians should document that the services are medically reasonable. CMS also noted that the proposal paves the way for new substance abuse treatment pathways, including virtual medication-assisted therapy.

Using the term “communication technology,” the agency said the scope of the law is limited to “a discrete set of physicians’ services that ordinarily involve, and are defined, coded, and paid for as if they were furnished during an in-person encounter between a patient and a health care professional.”

According to the proposal, Medicare would pay $14 per visit for virtual check-ins, a fraction of the cost of a $92 patient visit. Although CMS estimates it would pay for less than 1 million visits in the first year of the program, utilization would eventually reach an estimated 19 million per year. That 0.2% increase to Medicare costs would be offset by a 0.2% reduction in the “conversion factor” to maintain budget neutrality.

Whether that payment is high enough to incentivize physicians to utilize virtual technology remains to be seen, but it is added reimbursement for something many physicians are already doing.

Home Health PPS

CMS is proposing to define remote patient monitoring in regulation for the Medicare home health benefit and to include the cost of remote patient monitoring as an allowable cost on the HHA cost report. 

Defining remote patient monitoring and including such costs as allowable costs on the HHA cost report could encourage more HHAs to adopt the technology. Further attributing this cost for existing users from administrative or overhead costs are an important component to illustrating home health expenses and margins.

Intersection

More importantly, it is the ability of the home health agency’s adoption and incorporation of remote monitoring to their work that physicians would be able to expand their ‘virtual interactions.’  This is a hand-in-glove scenario and it is important that this adoption be reflected in your business relationships with referring physicians.

ElevatingHOME will be commenting on both the proposed home health prospective payment system and the proposed physician prospective payment system. Templated will be provided to members to support advocacy efforts. Please contact Joy Cameron with any questions.


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