This article outlines the basics of the model and considerations for those contemplating building a virtual care network. It also contains a simple graphic of the model, which can be helpful for visual learners
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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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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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On Monday, August 3, 2020, the Centers for Medicare & Medicaid Services (“CMS”) released the 2021 Medicare Physician Fee Schedule Proposed Rule (the “Proposed Rule”). The 2021 Proposed Rule includes a new code under the Behavioral Health Integration (“BHI”) Collaborative Care Model (“CoCM”) that, if finalized, would offer reimbursement for a shorter increment of time than had previously been available under BHI.
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On August 3, 2020, the Centers for Medicare & Medicaid Services (“CMS”) released it Proposed Medicare Physician Fee Schedule for CY 2021 (“Proposed MPFS”), seeking to expand reimbursement for Virtual Check-ins and e-Visits as a way of improving access to patient care. CMS proposes seven new HCPCS codes for these “Communication Technology-Based Services” that could be billed by practitioners who cannot bill Evaluation and Management (“E/M”) services independently.
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Carrie Nixon, of the Nixon Law Group, said the order calls for “a strategy to improve rural health by improving the communications infrastructure in rural America,” though she notes such a strategy would have to be funded.
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Nixon Law Group’s Managing Partner, Carrie Nixon, was quoted in an article appearing in Internet of Things World Today discussing the future of telehealth.
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Nixon Law Group’s Managing Partner, Carrie Nixon, was quoted in an op-ed for The Hill discussing 5 actions to fuel the digital health momentum. "The COVID-19 public health emergency has forcefully opened the door for widespread adoption of telehealth, remote patient monitoring, and other digital health platforms by patients and providers alike."
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Nixon Law Group’s Managing Partner, Carrie Nixon, was quoted in an article appearing in Modern Healthcare discussing the Senate HELP Committee hearing on telehealth that took place on June 17, 2020. The article notes general consensus among Committee members on two areas set forth as priorities by the Committee’s Chair, including 1) making permanent the elimination of the originating site and geographic restrictions for Medicare reimbursement of telehealth visits; and 2) maintaining and potentially expanding the list of services that may be provided by telehealth under Medicare, along with the list of types of healthcare providers eligible to provide these services to Medicare beneficiaries.
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Nixon Law Group’s Partner, Rebecca Gwilt, was quoted extensively in an article appearing in Home Health Care News regarding her views on the legal case for home health telehealth reimbursement.
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The Center for Medicare and Medicaid Services (“CMS”) has issued a second Interim Final Rule (“IFR2”) that includes additional expansions and clarifications relating to the provision and reimbursement of telehealth, remote patient monitoring, and telephone services during the COVID-19 Public Health Emergency (“PHE”). While these expansions are another step forward for the adoption of digital technologies and services in healthcare, there are additional changes needed in the near-term, as detailed in the summary below.
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‘We'll likely need a legislative change for these changes to be permanent,’ said Nixon. ‘There will be more of an impetus now. Once patients have had telehealth, it's likely they won't want to go back.’”
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Join us for a webinar to explain the most recent regulatory and reimbursement changes around the Remote Patient Monitoring, Telehealth, e-Visit, and Virtual Check-in CPT codes, during COVID-19, and what those changes mean from a practical perspective.
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“Widening use of telehealth and remote monitoring could lead to broader recognition among health-care providers and lawmakers of the value of these technologies and the need to reimburse for them appropriately, even after this crisis subsides, said Carrie Nixon of Nixon Law Group and an advisor to health-care venture firm Empactful Capital.”
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When the Coronavirus Preparedness and Response Supplemental Appropriations Act of 2020 was signed into law on March 6th, a provision in the Act that waives the geographic and originating site restrictions on telehealth services for the elderly garnered less attention, but could have a very important role to play in combatting COVID-19 - particularly if the waiver authority is further expanded by Congress. Learn more about the emergency telehealth waivers.
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