On November 1, 2018, CMS issued a 2,379 page final rule titled “Revisions to Payment Policies under the Medicare Physician Fee Schedule, Quality Payment Program and Other Revisions to Part B for CY 2019.” While there are some interesting changes related to remote patient monitoring for chronic kidney disease patients and loosening of originating site requirements for certain behavioral health services, most notable is the new “virtual check-in” code (HCPCS code G2012). Traditionally, CMS viewed brief telephone calls as non-billable, deeming the services rendered by providers to patients on such calls to be merely ancillary and included in an office visit. Conversely, the only way to bill for the exchange was to conduct the office visit.
The stated purpose of the “virtual check-in” code is for the billing provider herself (not her clinical staff) “to assess whether the patient’s condition necessitates an office visit.” To the extent the in-person visits are rendered unnecessary by the “virtual check-in,” both CMS and the patient save money.
Here are some of the interesting highlights of the new virtual check-in reimbursement rules:
- The “virtual check-in” can be used only with an established patient of the provider.
- The permissible modality includes realtime audio-only telephone interactions in addition to synchronous, or two-way audio interactions that are enhanced with video or other kinds of data transmission. Communications exclusively by email, text, or voicemail are not reimbursable.
- To be reimbursable, the “virtual check-in” cannot relate to evaluation or management (E/M) services provided to the patient in the prior 7 days, nor can it relate to an E/M service or procedure in the ensuing 24 hours.
- Only a billing provider eligible to bill for E/M services may bill this code.
- The “virtual check-in” must be medically reasonable and necessary.
- Patients will have to pay a co-pay on this service, thus the patient’s verbal consent to the visit and responsibility for the copay must be noted in the medical record.
- The anticipated reimbursement rate will be $14 per “virtual check-in.”
For more information contact Marc I. Goldsand, Esq. at [email protected]; (786) 871-3935.