Posts in Medicare Physician Fee Schedule
New Reimbursement Opportunities for Digital Mental Health Treatment in 2025: CMS’ Final Rule

See what the final Medicare Physician Fee Schedule for 2025 has to say about Digital Mental Health Treatment

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Top Six Takeaways from the Proposed 2023 Medicare Physician Fee Schedule: New Remote Monitoring, Behavioral Health, and Chronic Pain Care Management Codes and Telehealth Flexibility Extension

The much-anticipated 2023 Medicare Physician Fee Schedule Proposed Rule from CMS has arrived! More detailed analyses from the Nixon Gwilt Law team will follow, but in the meantime, here are our top takeaways from the 2023 Proposed Rule.

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Telehealth in the 2022 Medicare Physician Fee Schedule: Audio-Only Telehealth for Mental Health Made Permanent, and CMS Punts on Remote Direct Supervision

On November 2, 2021, the Centers for Medicare and Medicaid Services (“CMS”) finalized the Medicare Physician Fee Schedule for Calendar Year 2022 (the “Final 2022 MPFS” or the “Final Rule”). As we noted in our July article discussing the Proposed 2022 MPFS, CMS made some significant proposed changes to allow for audio-only telehealth in some limited circumstances. In addition, the agency also proposed to enable remote “direct supervision,” which would allow practitioners to supervise clinical staff billing incident to their services as long as they could be available by audio/video communication as necessary.

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Additional Reimbursement for Chronic Care Management and Principal Care Management Finalized in the 2022 MPFS

In the Final Medicare Physician Fee Schedule (“MPFS”) for 2022 (the “Final Rule”) issued on November 2, 2021, the Centers for Medicare and Medicaid Services (“CMS”) added five new CPT codes in the categories of Chronic Care Management (“CCM”) and Principal Care Management (“PCM”) and increased reimbursement for already existing codes in the same categories. Despite stakeholder feedback, CMS refrained from making any changes to the existing rules for obtaining beneficiary consent for CCM and PCM.

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Under 2022 Medicare Physician Fee Schedule, Physician Assistants Will Be Paid Directly for Services

On November 2, 2021, the Centers for Medicare and Medicaid Services (“CMS”) released its Final Medicare Physician Fee Schedule for 2022 (the “Final 2022 MPFS”), revising certain payment policies for services provided to Medicare beneficiaries by healthcare practitioners. These policies take effect on January 1, 2022.

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Proposed 2022 MPFS: Expansion in Audio-Only Telehealth, Permanent Remote “Direct Supervision”, and Remaining Opportunities for New Permanent Telehealth Codes

CMS didn’t propose to add any permanent telehealth codes, but did incrementally expand patient access to telehealth in other ways.

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New Remote Therapeutic Monitoring CPT codes introduced in Proposed 2022 Medicare Physician Fee Schedule

On July 13th, the Centers for Medicare and Medicaid Services (“CMS”) released its proposed Medicare Physician Fee Schedule for Calendar Year 2022 (the “2022 Proposed MPFS” or the “Proposed Rule”). In doing so, it recognized five new CPT codes for Remote Therapeutic Monitoring (“RTM”) of “non-physiologic” patient data such as “musculoskeletal system status, respiratory system status, therapy (medication) adherence, and therapy (medication) response” as well as pain. While this new code set is welcomed by advocates for virtual care, the 2022 Proposed MPFS that discusses RTM may raise just as many questions as it answers.

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Carrie Nixon in mHealth Intelligence Discussing the 2021 MPFS Reimbursements for RPM

Nixon Gwilt Law’s Managing Partner, Carrie Nixon, was quoted in an article appearing in mHealth Intelligence discussing the January amendments by the Centers for Medicare & Medicaid Services to the 2021 Physician Fee Schedule to clarify reimbursement for remote patient monitoring programs.

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Carrie Nixon in mHealth Intelligence Discussing the 2021 Medicare Physician Fee Schedule

Nixon Gwilt Law’s Managing Partner, Carrie Nixon, was quoted in an article appearing in mHealth Intelligence discussing the recent changes to Telehealth and Remote Patient Monitoring with the new 2021 Medicare Physician Fee Schedule (learn about our take here and here).

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Remote Patient Monitoring in the 2021 Medicare Physician Fee Schedule: The good, the bad, and the ugly

On December 1, 2020, the Centers for Medicare and Medicaid Services (“CMS”) released its Final Medicare Physician Fee Schedule for 2021 (the “Final 2021 MPFS”), revising payment policies for services provided to Medicare beneficiaries by medical practitioners. These policies will take effect on January 1, 2021. Read on for insights from Team NGL.

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