New Telehealth Policies in Medicare 2021 Physician Fee Schedule
The changes for 2021 are designed to expand the use of telehealth technologies among Medicare beneficiaries.
The changes in the Final Rule include:
1. Direct Supervision via Telehealth
Until the end of the PHE (tentatively 1/21/2021) “direct supervision” can be provided using real-time, interactive audio-video technology. CMS will study and collect data on whether this change may be appropriate on a permanent basis after the PHE expires.
2. Extended Audio-Only Assessment Services: HCPCS G2252
On an interim basis for the duration of 2021, CMS created HCPCS code G2252 for extended services delivered via synchronous communications technology, including audio-only (e.g., virtual check-ins). The service is considered to be a communication technology-based service (CTBS) and is subject to all the other requirements of CTBS.
- G2252 (Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, 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; 11-20 minutes of medical discussion. Direct PE of 3 minutes for clinical labor, and 1 minute, 15 minutes and 5 minutes for pre-, intra- and post-service time.) It has a RVU of 0.5.
- G2252 is cross-walked to CPT code 99442 for reimbursement purposes, making its reimbursement higher than the current more limited duration virtual check-in code. The code is intended for situations when the acuity of a patient’s problem is not necessarily likely to warrant an in-person visit, but when additional time is needed to make this assessment. Because it is a CTBS, the traditional Telehealth Service location restrictions do not apply, which in part means G2252 can be used regardless of the patient’s geographic location and will be used beyond the PHE.
3. New Frequency Limitations for Telehealth in Nursing Facilities
CMS is reducing the frequency limitation for coverage of subsequent nursing facility care services furnished via telehealth from once every 30 days to once every 14 days.
4. Policies on Communications Technology Based Services
CTBS by Therapists. HCPCS codes G2061 through G2063 may be billed by licensed clinical social workers, clinical psychologists, physical therapists (PT), occupational therapists (OT), speech language pathologists (SLP), and other non-physician practitioners who bill Medicare directly for their services, when the service falls within the scope of the practitioner’s benefit category. This billing has been temporarily allowed under the PHE waivers, but this new rule change is permanent, effective January 1, 2021.
5. New Telehealth Services
CMS is permanently adding these codes for permanent additions to the Medicare Telehealth service list:
- Group Psychotherapy (CPT 90853)
- Domiciliary, Rest Home, or Custodial Care services, Established patients (CPT 99334-99335)
- Home Visits, Established Patient (CPT 99347-99348)
- Cognitive Assessment and Care Planning Services (CPT 99483)
- Visit Complexity Inherent to Certain Office/Outpatient E/M (HCPCS G2211)
- Psychological and Neuropsychological Testing (CPT 96121)
- Prolonged Services (HCPCS G2212)
The phone calls 99441, 99442 and 999443 will continue to be paid until the PHE is over (tentatively 1/21/2021) unless it is extended. CMS states it does not have the authority to pay for audio-only E&M services after expiration of the PHE. CMS established new coding and payment, outside of the PHE, for an extended audio-only virtual check-in service (HCPCS code G2252). CMS did not propose or finalize any changes to the originating site requirement. When the PHE expires, telehealth services will again only be available to beneficiaries in rural areas who travel to an originating site to receive the telehealth service, with some exceptions.