2019 Proposed Medicare Fee Schedule

Tucker Arensberg, P.C.
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The 2019 proposed Medicare Fee Schedule was published on July 27, 2018 by CMS at https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-14985.pdf.

Pages 61 through 91 of the Executive Summary are devoted to: Modernizing Medicare Physician Payment by Recognizing Communication Technology-Based Services.  Click here to read: Modernizing Medicare Physician Payment by Recognizing Communication Technology-Based Services.

This subsection is devoted to explaining both additions to the existing list of covered Medicare Telehealth Services and an identification of and an explanation for covering those additional services by Medicare.

CMS is careful to distinguish its process for simply adding services to the existing list of covered Medicare Telehealth Services and the addition of new types of services outside of the existing telehealth structure.  CMS believes that simply adding services to the existing list of Medicare telehealth services would require those additional services to be subject to the limitations on Medicare telehealth services as established in Section 1834(m) of the Social Security Act, which CMS do not intend to do.

Following is a list of discrete technology base services which CMS proposed to add as separately identifiable physician services payable under the Medicare Physician Fee Schedule, and for which CMS is seeking comment:

  1. Brief Communication Technology-Based Service, e.g. virtual check-in (HCPCS Code GVCI1)
  2. Remote Evaluation of Pre-Recorded Patient Information (HCPCS Code GRAS1)
  3. Interprofessional Internet Consultation (CPT Codes 994×6, 994×0, 99446, 99447, 99448 and 99449)

The attached pages of the Executive Summary go into great detail regarding the explanation of these types of services, and explaining in the blog post would occupy too much space but you can refer directly to the attached executive summary.

On page 74 of the attached summary, CMS provides an additional list of services they propose to expand under Section 1834(m) of the Social Security Act.  You should refer to the Executive Summary for that as well.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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