On November 1, 2018, the Centers for Medicare & Medicaid Services issued a final rule that updated payment policies and rates under the Medicare Physician Fee Schedule (PFS). This rule also formalized two types of remote service offerings known as “virtual check-ins” and “store and forwards.” In an effort to increase access for Medicare beneficiaries, CMS has recognized and finalized a code to provide separate payment for communication technology “virtual check-in” service. The purpose of these services are “brief check-ins” using communication technology to evaluate whether or not an office visit is warranted. Currently, these types of services would be bundled into the payment for the resulting visit, such as through an evaluation and management visit code. However, not all of these communications lead to an office visit. Subsequently, there is no service the communication can be bundled into. CMS believes that these communications are becoming more frequent and more effective at addressing patient concerns. CMS goes so far as to state that “better practitioners” are leveraging technology to furnish check-ins and mitigate unnecessary office visits.
Beginning on January 1, 2019, this newly defined type of physicians’ service furnished using communication technology will be separately payable. The HCPCS code will be G2012 and is described as: “Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.”
CMS states that it will not be more descriptive in defining “communication technology” because it recognizes that technology could change over time and it does not wish to limit or exclude certain interactions from this definition. Finally, CMS will require verbal consent from beneficiaries to be noted in the medical record for each service and such services are limited only to established patients.
CMS has also finalized a specific code for the remote professional evaluation of patient-transmitted information conducted via pre-recorded “store and forward” video or image technology. CMS stated that much like the “virtual check-in” service, the purpose of this service is to determine whether or not an office visit is necessary. As such, it increases access for Medicare beneficiaries. This service can only be separately billable if the interaction does not result in an office visit within 7 days of the remote service or does not originate from a related office visit from 7 days prior. The HCPCS code will be G2010 and is described as: “Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment.” Like the “virtual check-in” service, this service also requires verbal consent for each service.
This post is part of a series analyzing changes in the 2019 PFS Final Rule; please see here for other posts related to the PFS Final Rule.