On July 12, 2018, the Centers for Medicare & Medicaid Services (CMS) published the proposed 2019 revisions to the Medicare Physician Fee Schedule (PFS). The deadline for comments was September 10, 2018. Stay tuned for modifications, clarifications and subsequent implementation on January 1, 2019.

CMS limits telemedicine payment based on service, provider, technology, and patient location. CMS is considering reducing some of these restrictions. The goals are to increase access to care, reduce the need for an in-person office visits, and to support coordination of care and team-based care.

CMS is proposing to reimburse technology-assisted synchronous brief check-ins between patients and physicians. The check-ins would need to be with an established patient and occur more than seven days since the most recent Evaluation and Management (E/M) service with that physician and not lead to an E/M service with that physician within the next 24 hours or be the soonest available appointment.

CMS is proposing to reimburse physicians for evaluating patient-transmitted asynchronous video or still information ("store and forward") and verbally following up with that patient within 24 hours. Again, the patient-transmitted information would need to be more than seven days since the most recent E/M service with that physician and not lead to an E/M service with that physician within the next 24 hours or be the soonest available appointment. CMS requested comments regarding whether this service should be limited to established patients or new patients.

Regarding the brief technology assisted check-ins and patient transmitted information, CMS is proposing to waive the in-person requirement for Rural Health Centers and Federally Qualified Health Clinics.

CMS is considering reimbursing for technology assisted consultations. The consultation would need to include a verbal and written report to the patient’s treating or requesting physician or other qualified health care professional.

CMS is considering developing a separate bundled payment for Substance Use Disorders treatment including Medication Assisted Therapy and web-based counseling.

CMS's proposals are a step toward reducing administrative and reimbursement obstacles to the use telemedicine.

In its letter to the Administration, APA has expressed support for these proposals.

About the Author

Alexander von Hafften, M.D., DFAPA
Member
APA Committee on Telepsychiatry