The Centers for Medicare and Medicaid (CMS) published a 200-page interim final rule March 30 that makes a number of changes to Medicare policy as well as greatly expanding telehealth coverage. The new policies apply retroactively to March 1, 2020 for the duration of the Public Health Emergency. Below are the changes that are most relevant to allergy:
- Phone calls: Medicare will now pay for phone calls (audio-only) using existing CPT Codes 99441-443 (for clinicians) and 98966-68 for clinical staff. The code selection is based on time. Reimbursement ranges from about $14 to $41.
- Non-facility for rate for telehealth E/M: Medicare will pay the higher non-facility rate for telehealth visits during the public health emergency. This policy is retroactive to March 1, 2020. As a result, physician claims should use the place of service code that would apply if the services were provided in person and should not use POS 2. They should use modifier 95 to indicate the service was provided via telehealth.
- Cost sharing waiver: Medicare will allow waiver of deductibles and coinsurance for telehealth and communication technology-based services. This does not require physicians to waive co-insurance.
- New patients: virtual check-ins and digital visits (G2012 and CPT Codes 9941-423) can be provided to new patients now – not just established patients.
- Supervision of incident-to services: Direct (i.e., on-site) supervision required for incident to services and for certain diagnostic tests can be performed via audio/visual real time communications technology.
- Evaluation and management coding: CMS will allow telehealth visits to be coded based on medical decision-making or time regardless of whether counselling and coordination of care comprise 50% of the visit. This is similar to the policy that will be in place in 2021 for all services although currently it only applies to outpatient visits furnished via telehealth during the public health emergency.
- Expansion of covered telehealth services: Medicare will now cover a range of E/M services provided via telehealth including home visits, domiciliary visits, critical care, and emergency department visits.