What COVID-19 kick-started, the Centers for Medicare & Medicaid Services endorsed in the 2021 Medicare Physician Fee Schedule, adding a list of reimbursable telehealth services.
“The American College of Physicians is pleased that CMS has made the expansion of telehealth a priority in the physician fee schedule,” says Brian Outland, the College’s director of regulatory affairs. “The flexibilities that were put in place earlier in the COVID-19 pandemic have been important for patients to access care, and important for physicians to keep their practices open and operating. Many physician practices have faced dire financial situations while we have been dealing with the COVID-19 pandemic. While telehealth visits won’t make up for that entirely, they do help to keep practices open and help patients who would avoid in-person visits to access care.”
Before the COVID-19 public health emergency (PHE), only 15,000 fee-for-service beneficiaries each week received a Medicare telemedicine service, according to CMS. Under a special waiver for the PHE in March 2020, Medicare was authorized to pay for office, hospital, and other visits furnished via telehealth, including those originating in patients’ places of residence. Preliminary data shows that between mid-March and mid-October 2020, over 24.5 million out of 63 million beneficiaries and enrollees received a Medicare telemedicine service.
Services added to the Medicare telehealth list in the 2021 Physician Fee Schedule include “domiciliary, rest home or custodial care services,” home visits with established patients, “cognitive assessment and care planning services,” and “visit complexity inherent to certain office/outpatient evaluation and management (E/M).” Additionally, CMS created a temporary category of criteria – called Category 3 – for services added to the Medicare telehealth list during the public health emergency that will remain on the list through the calendar year in which the PHE ends.
Despite some disappointment around CMS’ decisions regarding remote patient monitoring, the American Telemedicine Association believes that overall, the final rule is a positive step, says Kyle Zebley, director of public policy. “CMS has gone out of its way to think creatively.” Still, some roadblocks to fuller implementation of telehealth exist, he says.
For example, CMS lacks the authority to permanently permit reimbursement for home-based telehealth. “As it stands, you have to be at a provider’s location in order to have reimbursable telehealth,” says Zebley. “That is an outdated law written decades ago, and it needs to be changed.” But only Congress, through legislation, can make that happen. Likewise, only Congress can change existing law that (but for the public health emergency) restricts reimbursable telehealth services to patients in defined rural geographic locations, he says. “Of course, we believe telehealth should be available to those in rural areas, but we also think the law should cover telehealth services for Medicare recipients no matter where they live.”