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2019 Remote Communication Technology
Brief Communication Technology-Based Service
Brief communication technology-based service would include check-in services used to evaluate whether or not an office visit or other service is necessary. This service would be billable when a physician or other qualified health care professional has a brief non-face-to-face check-in with a patient via communication technology to assess whether the patient’s condition necessitates an office visit and when it does not result in an office visit.
GVCI1 - 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.
For instances when the brief communication technology-based service originates from a related E/M service provided within the previous 7 days by the same physician or other qualified health care professional, the service would be considered bundled into the previous E/M service and would not be separately billable. Likewise, if the service leads to an E/M in-person service with the same provider within 24 hours or the next available appointment it would also be bundled into the pre-visit time. However, if no visit is associated with the interaction it would be separately billable under GVCI1 and paid $14 under the proposal. CMS believes that through the check-ins practitioners would be able to mitigate the need for potentially unnecessary office visits. Only established patients would be eligible for this service. CMS does not propose any frequency limits on the code
Remote Professional Evaluation of Patient-Transmitted Information
CMS proposes creating a specific new code to describe remote professional evaluation of patient-transmitted information conducted via pre-recorded “store and forward” video or image technology. These services would not be subject to the Medicare telehealth restrictions because they could not substitute for an in-person service currently payable separately under the PFS. these services may be used to determine whether or not an office visit or other service is warranted.
GRAS1 - Remote evaluation of recorded video and/or images submitted by the patient (e.g., store and forward), including interpretation with verbal 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.
As is the case for the virtual check-ins described previously, in instances when the brief communication technology-based service originates from a related E/M service provided within the previous 7 days by the same physician or other qualified health care professional, the service would be considered bundled into the previous E/M service and would not be separately billable. Likewise, if the service leads to an E/M in-person service with the same provider within 24 hours or the next available appointment it would also be bundled into the pre-visit time. If neither of these scenarios occurs, then the service is a stand-alone service that is separately billed. CMS plans to value the service by a direct crosswalk to CPT code 93793 which in 2018 paid $12.24. CMS notes that this would be distinct from the brief communication technology-based service described above in that this service involves the practitioner’s evaluation of a patient-generated still or video image, and the subsequent communication of the resulting response to the patient, while the brief communication technology-based service describes a service that occurs in real time and does not involve the transmission of any recorded image.
Interprofessional Internet Consultation
The addition of interprofessional internet consultation codes would cover consultations between professionals performed via communications technology such as telephone or Internet. is would support a team-based approach to care that is often facilitated by electronic medical record technology. They propose to pay separately for each code and requests that the Relative Value Scale (RVS) Update Committee (RUC) at the American Medical Association assists in establishing values for the six CPT codes.
99446-99449 - Interprofessional telephone/Internet assessment and management service provided by a consultative physician including a verbal and written report to the patient's treating/requesting physician or other qualified health care professional; 5-31 minutes of medical consultative discussion and review (depending on code).
994X0 - Interprofessional telephone/Internet/electronic health record referral service(s) provided by a treating/requesting physician or qualified health care professional, 30 minutes
994X6 - Interprofessional telephone/Internet/electronic health record assessment and management service provided by a consultative physician including a written report to the patient’s treating/requesting physician or other qualified health care professional, 5 or more minutes of medical consultative time
Providers would be required to obtain verbal consent, which would include making the patient aware of any cost sharing that may be applicable, in advance of the services and document the consent in the patient medical record.
CMS introduced three new RPM codes, retitled “Chronic Care Remote Physiologic Monitoring,” which largely adopt the new codes created by the American Medical Association in 2017. The codes (CPT 990X0, 990X1, and 994X9) are intended to better reflect how RPM services can be delivered to patients.