2019 Physician Fee Schedule and Telehealth

Posted on 15 Oct, 2018 |comments_icon 0|By Bruce Pegg

Virtual Visits, Real Reimbursement: Telehealth and the 2019 Physician Fee Schedule

While discussions about the way evaluation and management (E/M) coding could change may have dominated recent coding conversations surrounding the Centers for Medicare and Medicaid Services (CMS) proposed Medicare Physician Fee Schedule (MPFS), other equally important proposed changes to the field of telemedicine may have slipped under your radar.

If they have, now would be a good time to get up to speed. Because CMS is continuing its drive to modernize Medicare and give beneficiaries who face geographic struggles in accessing healthcare the chance to virtually connect with their providers. That means Medicare is planning on reimbursing for more telehealth services, which in turn gives you a chance to boost your bottom line.

It’s the Little Things

Let’s begin with two new HCPCS codes that may not seem like much, but which could add up to big things, both for your patients’ access to your providers and for your practice’s revenue stream. CMS’s proposed MPFS for 2019 includes plans to reimburse providers for virtual check-ins with the following

  • GVCI1 — Brief Communication Technology-based Service, e.g. Virtual Check-in
  • GRAS1 — Remote Evaluation of Recorded Video and/or Images Submitted by the Patient.

The first records simple phone, text, or email interactions between a patient and your provider regarding the status of a medical issue, while the second allows patients to send a video or an image, again via email or phone, to be evaluated by a provider to determine the severity of the condition and type of follow-up.

The codes are a win-win for all concerned. Patients get to send in quick health queries without having to leave home and wait in your office; providers get to determine the seriousness of a condition before committing valuable time to resolving it; and your billing office finally gets reimbursed for the service.

Consultation Remuneration

The 2019 MPFS also shows that CMS is committed to resolving a longstanding issue in reimbursement: compensating providers for consulting services. Medicare’s policy of not reimbursing for these services seems about to change, at least as far as telehealth is concerned, with the revision of four existing codes and the addition of two more.

The codes in question are

  • 99446 — 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; 5-10 minutes of medical consultative discussion and review
  • 99447 — … 11-20 minutes …
  • 99448 — … 21-30 minutes …
  • 99449 — … 31 minutes or more …
  • 99451 — 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 minutes or more of medical consultative time; and
  • 99452 — Interprofessional telephone/Internet/electronic health record referral service(s) provided by a treating/requesting physician or other qualified health care professional, 30 minutes.

CMS’s proposal is to unbundle 99446-99449 and, for the first time in five years, make them separately reimbursable, while 99451-99452 now gives flexibility for the consulting physician to consult using the patient’s electronic health record, either for assessment and management or, in the case of 99452, for referral purposes.

Next Time: Are You Ready for the RPM Revolution?

Stay tuned for Part 2 of this series, where we’ll explore new E/M codes for remote patient monitoring that expand Medicare coverage of services using technology to connect with patients at home.

Learn More

Stay on top of the latest code and guideline changes, as well as regulatory updates and revisions to CCI bundles, modifiers, payer policies, the physician fee schedule, the OIG work plan, TPE, RACs, and more with Medicare Compliance & Reimbursement.

Leverage the advantages of telemedicine to build your practice volume with TCI’s best-in-class telemedince handbook. Our all-new, end-to-end The Telemedicine & Telehealth Handbook for Medical Practices 2018 will equip you to plan and implement your telehealth services, weigh the cost of care and technology, and master payment aspects, compliance, legal requirements, and much more.


Bruce Pegg
Editor, Newsletters

An experienced teacher and published author, Bruce is TCI’s new voice of primary care, delivering advice and insights every month for coders in the fields of family, internal, and pediatric medicine through Primary Care Coding Alert and Pediatric Coding Alert. Additionally, he is the current editor of E/M Coding Alert. Bruce has a Bachelor of Arts degree from Loughborough University in England and a Master of Arts degree from The College at Brockport, State University of New York. He recently became a Certified Professional Coder (CPC®), credentialed through AAPC.

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