Last week I posted a press release from the ATA about expanded Medicare coverage for Telemedicine. Well, I decided to actually read the 1200 page rulemaking from the Centers for Medicare and Medicaid Services (CMS). You can guess why it’s taken a week to write a follow up article…
Actually, no. I didn’t read the entire rulemaking, only the pages relevant to all things “tele” in medicine and healthcare. In doing so, I was reminded of something interesting:
There are a number of procedures already covered by Medicare without specific telemedicine codes. In fact, of the seven bullet points listing the 22 codes rejected or deleted from inclusion, five noted the affected codes were largely unnecessary due to either an existing telehealth code or because Medicare does not distinguish whether the procedure is tele or not.
Here are a few examples:
Regarding electrocardiograms and echocardiograms: “By definition,the [technical component] portion of these services needs to be furnished in the same location as the patient and thus cannot be furnished via telehealth.” But then…”Rather, these remote services are considered physicians’ services in the same way as services that are furnished in-person without the use of telecommunications technology; they are paid under the same conditions as in-person physicians’ services (with no requirements regarding permissible originating sites), and should be reported in the same way as other physicians’ services (that is, without the –GT or –GQ modifiers).” (all emphases mine)
Regarding psychological computer testing: “These services…are payable in the same way as other physicians’ services. These remote services are not Medicare telehealth services as defined under the Act; therefore…the restrictions that apply to telehealth services do not apply to these services.”
Two more illuminating quotes from these seven bullets: “These services are not separately payable by Medicare. It would be inappropriate to include services as telehealth services when Medicare does not otherwise make a separate payment for them,” and, “We note that some of the services that the requester had in mind may be billed under the telehealth office visit codes or the telehealth consultation G-codes.”
If you have been wary of implementing telemedicine due at least in part to questions about reimbursement, I implore you to read the CMS rulemaking, check their site for appropriate codes, and see if the specific procedures you’d like to perform remotely even require a separate telehealth code in the first place. There’s a chance Medicare treats them as if performed in-office or that another telehealth code already covers the procedure.
It’s worth finding out, don’t you think?
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