CMS's 2019 proposal makes broad strides in telehealth, interoperability, documentation

By Jonah Comstock
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The Centers for Medicare and Medicaid Services released its new proposed Physician Fee Schedule and Qualified Payment Program updates for 2019, and the announcement includes some big strides forward in promoting digital health technology, including widened telemedicine coverage, an overhaul of documentation requirements, and a new focus on interoperability.

"Today is a huge win for patients and providers as CMS is proposing historic changes to modernize Medicare and restore the doctor-patient relationship," CMS Administrator Seema Verma said on a conference call. "This proposal alone is one of the most significant reductions in provider burden undertaken by any administration."

On the telemedicine side, the proposal, if enacted, would mean CMS will begin paying physicians for "brief check-ins" via telemedicine as well as remote evaluation of images and videos taken by patients. It also expands the list of Part B services that can be offered by telehealth and adds mobile stroke units, dialysis facilities, and the homes of end-stage renal disease patients as valid originating sites for telemedicine visits.

"Under this proposal, Medicare will start paying for virtual check-ins, meaning patients can connect with their doctor by phone or video chat," Verma said. "Many times this type of check-in will resolve patient concerns in a convenient manner that gets them the care that they need and avoids unnecessary cost to the system. This is a big issue for our elderly and disabled populations where transportation can be a burden to care as well as to caregivers. We’re not intending to replace office visits but rather to augment them and provide new access points for patients."

The proposal isn't carte blanche for telemedicine reimbursement, but it is fairly open-ended. Notably, it would allow providers to bill for a telemedicine check-up that neither stems from nor is followed up by an in-person visit. 

"There are going to be many situations where a physician might say 'I’m going to need to see you in my office' but it could be a check-in where they come in for a visit and they want to talk to their doctor about the medication that they’re taking and how it’s impacting them, and [this gives] the ability for them to not have to come in physically to have that conversation with the doctor, but to be able to have that remotely," Verma said.

It will be difficult for services like Teladoc to make use of this reimbursement, however, since the proposed rule requires an established doctor-patient relationship. Interestingly, however, CMS seems open to new patient relationships for the store-and-forward option.

"We are seeking comment as to whether these services should be limited to established patients; or whether there are certain cases, like dermatological or ophthalmological services, where it might be appropriate for a new patient to receive these services," CMS wrote in the proposal.

Remote patient monitoring also gains ground from the proposal, according to a press release from ACT The App Association's Connected Health Initiative.

“While we continue to we parse through the Centers for Medicare and Medicaid Services (CMS) new proposed rulemaking, it is clear that our voice has been heard. We applaud CMS for its range of proposals to bring connected health tools into the continuum of care, including three new remote monitoring reimbursement codes in the Physician Fee Schedule. Last month, we gathered 50 connected health stakeholders to urge CMS Administrator Seema Verma to activate CPT codes 990X0, 990X1, and 994X9 to reimburse for chronic care remote physiologic monitoring. Today, CMS proposed those new codes in its latest schedule."

The proposal also greatly eases documentation requirements, with the intent of allowing EHR developers to build tools geared towards patient care rather than satisfying billing requirements. CMS estimates the changes could save clinicians an estimated 29,305 hours and approximately $2.6 million in reduced administrative costs over a year. It works by standardizing the requirements among different evaluation and management (E&M) codes. 

"Doctors should not be spending time typing information into a computer simply in order to bill a certain level of code. They should focus on documenting the material that’s needed to capture the patient’s health data. Therefore we are proposing to move from a system with four kinds of documentation requirements to a system with one set of documentation requirements. There will still be four distinct code levels, but the differences will be meaningless. There will be one set of documentation requirements."

Finally, the proposal includes changes to the Merit-based Incentive Payment System (MIPS) “Promoting Interoperability” performance category, with the goal of encouraging patient access to their health information and aligning the program with the Office of Innovation's MyHealthEData Initiative.