Telehealth for Treatment of Substance Use Disorders

As part of the CY 2019 Medicare Physician Fee Schedule (PFS), the Centers for Medicare and Medicaid Services (CMS) issued an interim final rule with comment period to expand the use of telehealth for the treatment of substance use disorders and co-occurring mental health disorders. Existing law provides for reimbursement of telehealth services only if the originating site is located in a rural health professional shortage area, is not in a metropolitan statistical area or is an entity that participates in a federal telemedicine demonstration project. The originating site must also be one of a specific type of facility, such as a hospital, physician’s office or skilled nursing facility. With respect to telehealth services used to treat a substance use disorder or co-occurring mental health disorders, the interim final rule removes the originating site geographic restrictions and permits a patient’s home to be an originating site. When the patient’s home is used as the originating site for telehealth services, Medicare will pay no facility fee. The interim final rule is effective for telehealth services performed on or after July 1, 2019. CMS is requesting comments on the interim final rule, and the comment period closes January 22, 2019.

Expansion of Medicare Telehealth Services

The Bipartisan Budget Act of 2018 (BBA) permits patients with end-stage renal disease (ESRD) who undergo dialysis at home to receive monthly assessments by telehealth. The BBA also removed restrictions on the originating site geographic limitations and facility types where acute stroke telehealth services may be provided. The PFS implements these changes by adding renal dialysis facility and the patient’s home as telehealth originating sites for purposes of the monthly ESRD assessment. Medicare will pay no facility fee where the patient’s home is used as the originating site. CMS is also removing the geographic limitations on the originating site (i) with respect to ESRD-related telehealth services where the originating site is a hospital-based or critical access hospital-based renal dialysis center, a renal dialysis facility or the patient’s home; and (ii) where acute stroke telehealth services are provided. Finally, CMS is adding “mobile stroke units” as permissible telehealth originating sites for purposes of acute stroke telehealth services. The PFS defines “mobile stroke unit” as a mobile unit that diagnoses, evaluates and/or treats symptoms from an acute stroke. These changes are effective for telehealth services provided on or after January 1, 2019.

CMS reimburses only certain categories of telehealth services, which are delineated by HCPCS codes. On an annual basis CMS reviews proposed additions to the current list of codes to determine if additional codes should be added to the list of reimbursable telehealth services. Under the PFS and beginning January 1, 2019, CMS is adding to the list of reimbursable telehealth services HCPCS codes G0513 and G0514, which are codes for prolonged preventative services.

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.