Usually, clinical observation allows the practitioner to be physically present in the office and readily available to offer support and advice during the duration of the operation. As this demands that the billing clinician be present on-site, it is essential for the billing clinician to closely supervise the care rendered in a telehealth incident-their medical assistance by the auxiliary workers.
The current concept of direct supervision is focused on the assumption that the services rendered by the medical providers of the qualifying remote site clinician should be identified as they fulfill the direct supervision criteria at both the source and distant locations by the simulated intervention of the billing practitioner. However, the time during which this reform is appropriate is restricted because universal simulated direct observation may not be secure in all clinical contexts.
The Proposed New HCPCS Codes
Addition of services to Medicare telehealth services list: The nine new HCPCS codes that CMS is proposing for a permanent addition to the Medicare telehealth list include:
90853 – Group Psychotherapy
99334, 99335 – Domiciliary, Rest Home, or Custodial Care Services
99347, 99248 – Home Visits
GPC1X – Visit Complexity Associated with Certain Office/Outpatient E/Ms
99483 – Cognitive Assessment and Care Planning Services
96121- Psychological and Neuropsychological Testing
CMS aims to establish a new set of conditions for providers’ inclusion in the Medicare Telehealth Resources Program. The facilities to be included during the COVID-19 PHE and to stay indefinitely on the list are:
99336, 99337 – Domiciliary, Rest Home, or Custodial Care Services
99349, 99350 – Home Visits, Established Patient
99281, 99282, 99283 – Emergency Department Visits
99315, 99316 – Nursing Facilities Discharge Day Management
96130, 96131, 96132, 96133 – Psychological and Neuropsychological Testing
Additional guidelines on community-based technology services (CTBS): CMS describes communication technology-based services (CTBS) as programs that can be provided through telecommunications technology but are not called Medicare telehealth programs. CMS suggested that registered professional social workers pay HCPCS codes G2061-G2063, behavioral counselors, physical trainers, occupational therapists, and speech-language pathologists who reimburse Medicare explicitly for their services unless the treatment is given comes beyond the limits of the insurance divisions of such professionals. The CMS aims to implement this strategy permanently. CMS proposes two additional HCPCS Level II G codes that may be billed by individual non-physician practitioners who can not separately charge for E / M services:
G20X0 – Remote evaluation of captured video and photographs sent by the identified patient (e.g., shop and forward), including analysis of patient follow-up within 24 business hours, not emanating from a similar service rendered during the preceding seven days or referring to a facility or treatment during the next 24 hours or the earliest appropriate appointment.
G20X2 – Brief information technology-based support, e.g., remote control, given to a well-established patient by a qualified health professional who is unable to obtain medical and care services, not arising from a specific E / M service delivered within the previous seven days or referring to a facility or activity during the next 24 hours or the earliest available appointment; 5-10 minutes
To facilitate billing of CTBS, Therapists recommend that HCPCS codes G20X0, G20X2, G2061, G2062, and G2063 be applied to as “daily counseling” programs. When paid for a private practitioner PT, OT, or SLP, the codes will contain the accompanying GO, GP, or GN Counseling Suffix to signify that the CTB is given as a medical facility offered by the OT, PT, or SLP Care Program. CMS demanded a series of updates and clarifications on the related field of operation and specific issues in the rule framework. For instance, under the plan, the CMS will authorize CNMs, CNSs, NPs, and PAs — other than physicians — to manage the execution of diagnostic tests within their state-of-the-art framework and relevant state regulations, as long as they retain the necessary partnership with collaborating or overseeing physicians. CMS has also incorporated these provisions under the federal PHE resolution, but the Department is pushing to make the provision effective.
Looking Ahead in the Future
Looking Ahead in the FutureUnder the new law, CMS will also apply the regulations adopted under the PHE resolution of facilities rendered by pharmacists and physical therapists and other autonomy linked to examining and authenticating medical information. CMS needs the publics input about how to expand any consistency in Medicare compensation for teaching facilities.
The improvements to telehealth systems under the new regulation are relatively minor and are aligned with CMS Administrator Seema Verma’s aspirations over the last two months. The primary focus of CMS appears to be the development of telehealth facilities. CMS also recognized that audio-only experiences are of benefit to patients. The Agency has presented a particular illustration in the fact sheet on the new rule: people who wish to be cared for but choose to prevent future access to Covid-19 in a clinical environment. However, as with other clinicians consulted by the Advisory Board of Experts, CMS remains unsure of an audio-only session’s therapeutic importance. There are obvious limitations to the kind of examination possible in an audio-only interaction. CMS also recognized that audio-only experiences are of benefit to patients. The Agency has presented a particular illustration in the fact sheet on the new rule: people who wish to be cared for but choose to prevent future access to Covid-19 in a clinical environment. However, as with other clinicians consulted by the Advisory Board of Experts, CMS remains unsure of an audio-only session’s therapeutic importance.
