Winter 2015 - Plasma

Telehealth Payments and Domain to Expand Under Proposed CMS Rule

A 609-page proposed rule by the Centers for Medicare and Medicaid Services (CMS) would add to the list of Medicare-reimbursable telehealth activities, as well as pay for telehealth services in rural areas nearer big cities under a geographical expansion. The proposal would add annual wellness visits to the list of telehealth services for both the initial visit and subsequent visits if they include a personalized prevention plan of service. In addition, it would add psychoanalysis, family psychotherapy (both with and without the patient being present) and “prolonged service in the office or other outpatient setting requiring direct patient contact beyond the usual service.” Payments for telehealth services would be afforded to patients in “rural census tracts” even if those tracts are within metropolitan statistical areas. Census tracts are composed of smaller census blocks and block groups and have, on average, about 4,000 inhabitants.

Existing CMS payment policy and the agency’s new telehealth payment proposal model a telehealth policy guide approved in April by the Federation of State Medical Boards (FSMB), which says that a physician-patient relationship must be established for physicians to engage in telemedicine, but that a relationship can be initiated “whether or not there has been an encounter in person between the physician (or other appropriately supervised healthcare practitioner) and patient.” In defining telemedicine, the FSMB states: “Generally, telemedicine is not an audio-only telephone conversation, email/instant messaging conversation or fax. It typically involves the application of secure videoconferencing or store-and-forward technology to provide or support healthcare delivery by replicating the interaction of a traditional encounter in person between a provider and a patient.” Existing Medicare policy, the new rule says, mandates that telehealth includes “at a minimum, audio and video … permitting two-way, real-time interactive communication.” Telephones and email “do not meet the definition of an interactive telecommunications system.” Medicare permits payments for “store-and-forward” technology in demonstration projects in Alaska and Hawaii.

BSTQ Staff
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