2017 Medicare Telehealth Changes

Tucker Arensberg, P.C.
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The 2017 Medicare Physician Fee Schedule finalizes the CMS changes for Telehealth reimbursement and coverage for 2017.  The CMS fee schedule document also provides a comprehensive explanation of Medicare Telehealth reimbursement and coverage.  I have excerpted those 35 pages and linked them as a PDF to this post: Medicare Telehealth Services.

The essential takeaways are as follows:

Technology:  Generally Medicare will require interactive technology for telehealth services, except for the approved use of asynchronous (store and forward) platforms for the demonstration projects in Alaska and Hawaii.

Location for Billing:  Telehealth services should be billed by the practitioner to the MAC servicing the distant site at which the providing physician is located; the patient is at the originating site, although it is possible that both will be in the same jurisdiction.

Improved Telehealth Services:  CMS explains its process for approving additional telehealth services, and provides the link to the existing list of covered services, i.e. https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/index.html.

Annual Covered Service Update:  CMS maintains a process for approving new services by separating services into two categories, i.e.

  • Category 1 has a protocol designed to review services similar to existing consultation, office visit, and office psychiatry services similar to those currently on the list of approved telehealth services.
  • Category 2 is a protocol for services that are not similar to the current list of telehealth services, and require demonstration as to how the service will improve the diagnosis or treatment with evidence of relevant clinical studies.

Additional Covered Services for 2017:

  • ESRD services similar to existing ESRD services
  • Advanced care planning using CPT codes 99497 and 99498
  • Critical care consultations using HCPCS codes G0508 and G0509

New Point of Service Reimbursement:  CMS is adding point of service (POS) codes for the distant site to distinguish reimbursement between facility and non-facility rates.  This change is also explained in MLN matters #MM9726, also linked as a PDF.

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM9726.pdf

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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