We may still be in the throes of the COVID-19 pandemic, but that isn’t stopping policy makers from planning ahead to determine whether temporary telemedicine CPT codes should be a permanent part of the “new normal” that is expected to reign after the emergency situation dissipates. As mentioned previously, quick changes to legislation, especially those that reimburse telemedicine visits at the same value as in-office visits, made telemedicine a much more convenient and financially viable alternative to the traditional model of in-office visits—for both patients and providers. As we look ahead to 2021, however, debate surrounds the Centers for Medicare and Medicaid Services (CMS)’ decision to drop a large majority of the recently-enacted billing codes, which may return the state of telemedicine almost to where it was before the pandemic began. At the same time, President Trump signed an Executive Order to improve access to care and convenience for Medicare patients who live in rural areas. These are positive, productive steps towards integrating telemedicine as a permanent part of healthcare delivery services, but do they go far enough?
The enthusiasm with which both patients and providers embraced telemedicine has prompted some industry experts to predict continued high levels of usage post-pandemic. As we’ve noted before, telemedicine has proven to be more convenient to patients and more suited for low-acuity cases, thereby reserving the in-office slots for higher acuity situations that need more hands-on diagnosis and care. However, at this stage, the newly-proposed CMS codes do not appear to fully endorse this approach.
While drafting its proposed 2021 Physician Fee Schedule, CMS examined all of the telehealth codes which have been enacted as an emergency measure for the pandemic. The rules were sorted into three categories:
- Category 1 – (9 codes) Temporary codes that will become permanent
- Category 2 – (74) Temporary codes that will dissolved due to a lack of clinical benefit
- Category 3 – (13) A new category intended for temporary codes that CMS believes would be useful if they become permanent, but CMS needs to gather more data, feedback, and real-world use experience before deciding whether to keep these codes.
How will these changes in telemedicine CPT codes affect patients and providers? An analysis by industry experts Foley & Lardner LLP expects these “bold” updates to focus on expanding the use of telemedicine for Medicare beneficiaries. The fact that CMS created Category 3 suggests that the organization is open to gradually raising telemedicine coverage in the domains that have been proven to be of clinical benefit. However, some industry analysts expressed concern that neither Trump’s Executive Order nor proposed CMS changes addresses the usage of telemedicine beyond rural areas.
CMS invites industry watchers, stakeholders, and the public to comment on the revised telemedicine CPT codes by October 5, 2020.
To read more about Trump’s Executive Order, visit CMS.gov.