A second wave of policy and payment changes that CMS released today is reshaping – yet again – how the medical community can conduct care during the COVID-19 crisis and, critically, how much providers can expect to get paid.
In a wide-ranging update to policy guidance that CMS is touting as a “second round of sweeping changes,” the agency seeks to further expand COVID care, ramp up diagnostic testing and again loosen restrictions on which types of providers can deliver vital services like telehealth during this unprecedented emergency.
Take stock of some of the key updates below, as Part B News continues to pore through the latest batch of waivers and policy changes.
Telephone services get a raise
A pay boost for telephone E/M services – approaching nearly a 200% rise in reimbursement – will give new meaning to the phrase “phoning it in” for practices that have provided and reported telephone E/M services (99441-99443) during the COVID-19 public health emergency (PHE).
As part of the drive to encourage the use of non-face-to-face services during the PHE CMS will “increase payments for these services from a range of about $14-$41 to about $46-$110,” CMS announced today. The updated payments will result in payments that are close to what you’d receive for new patient office visits 99201-99203.
Better still, the update is retroactive to March 1, so practices that have been reporting these services won’t miss out.
The move is similar to steps taken by states like Maryland that allow providers to report office E/M services conducted by audio-only means.
CMS notes that some patients can’t or won’t use a real-time audio/video connection that is required for a telehealth office visit. However, it appears that you will still need to report a telephone code for Medicare services. The codes will be added to the telehealth list, CMS states.
If this news makes your doctors and non-physician practitioners take a fresh look at telephone services, crack open your 2020 CPT manual and educate staff about the codes’ requirements. For example, the phone call can’t be related to a recent E/M service or lead to an in-person visit.
In addition, the codes are based on the time the clinician devotes to medical discussion. Make sure they’re keeping close track of their time your practice doesn’t experience an outbreak of over- or undercoding.
Telephone E/M services
Here’s a list of the currently covered telephone E/M services, which are set to see significant increases to their associated payment levels:
- 99441 (Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion).
- 99442 ( … ; 11-20 minutes of medical discussion).
- 99443 ( … ; 21-30 minutes of medical discussion).
Expanded diagnostic testing options
- Non-physician practitioners (NPP) can order COVID-19 tests – if state scope of practice allows. CMS says it is waiving its requirement for a written order from the treating physician or other practitioner for Medicare patients to obtain COVID-19 or related lab tests. Instead, during the public health emergency (PHE), the tests may be covered when ordered by “any healthcare professional authorized to do so under state law,” the agency states in its press release.
“To help ensure that Medicare beneficiaries have broad access to testing related to COVID-19, a written practitioner’s order is no longer required for the COVID-19 test for Medicare payment purposes,” CMS states in the press release.
CMS will also pay for tests conducted on homebound patients and in drive-through locations such as parking lots.
Providers as well as hospitals can bill and be paid separately for tests subsequent to patient assessment for COVID-19 and lab sample collection. Also, CMS will cover some antibody (serology) tests, and some FDA-authorized at-home tests conducted by beneficiaries. Heretofore CMS had authorized codes U0001 (for CDC-authorized tests), U0002 (for non-CDC-authorized tests), and the nasal probe test code 87635, which pay approximately $36, $51, and $51 dollars respectively; CMS says it is now adding the antibody test codes 86328 and 86769 (payment TBD), “lab test using high through-put technology” codes U0003 and U0004 ($100); and patient collected test codes C9803 (billed by hospital outpatient department), 99211 (collected by physician office), and G2023 and G2024 (billed by home health, nursing home, or lab for home health) billing $23-$25.
Outpatient departments can retain rates
- Some off-campus provider-based outpatient departments can apply for a temporary pay boost. Off-campus provider-based departments (PBDs) in recent years have seen their reimbursement reduced as it was based on physician fee schedule payment rates. Under the latest CMS expansion, some PBDs will be allowed to apply for a temporary exception so they can be paid based on hospital outpatient prospective payment system (OPPS) facility rates. CMS says it also will allow hospitals to relocate outpatient departments to more than one off-campus location, or to partially relocate to off-campus sites.
More telehealth updates
- CMS will now allow physical and occupational therapists to bill telehealth therapy codes. This is an expansion from the March 31 interim final rule, which added numerous therapy codes – including evaluations and re-evaluations – to the list of payable telehealth codes but barred therapists from billing for telehealth services. CMS now will allow PTs, OTs and speech language pathologists to provide care via telehealth. In addition, CMS says it will allow Medicare reimbursement for therapy assistants who provide “maintenance therapy services” in the outpatient setting. “This frees up physical and occupational therapists to perform other important services and improve beneficiary access,” CMS states.
- Expect additional telehealth services to hit the master list. CMS already approved dozens of additional services to be eligible for telehealth during the PHE. With a tweak to how it decides which services are eligible, you can expect to see more come online. “Until now, CMS only added new services to the list of Medicare services that may be furnished via telehealth using its rulemaking process,” the agency says. “CMS is changing its process during the emergency, and will add new telehealth services on a sub-regulatory basis, considering requests by practitioners now learning to use telehealth as broadly as possible. This will speed up the process of adding services.”