Post Date: November 7, 2016

The Center for Medical and Medicaid Services (CMS) has received numerous calls from stakeholders to add telehealth service as Medicare-covered service. In response, it suggested an additional number of telehealth services eligible for Medicare reimbursement. Also, adjustment of Place of Service (POS) coding policies was proposed.

Eligibility for Reimbursement

For telehealth service to qualify for reimbursement, it must be:
• Listed as a defined set of service
• Rendered at an authorized location such as hospitals
• Administered by a licensed provider like physicians
• Provided using a particular telecommunication technology

CMS has acknowledged telehealth value through continuous additional of services that are eligible for reimbursement. In the Proposed Rule, CMS intends to add the following services to the list of those eligible for Medicare reimbursement:

• Consultations in critical care
• Advance care planning
• Services related to end-stage renal condition

Regarded but Declined

CMS received requests, which didn’t meet its set guidelines for reimbursable services. The following procedures were contemplated but they were declined:
• Emergency department services
• Observation services
• Physical therapy
• Speech-language pathology
• Psychological testing
• Occupational therapy

CMS referred to its cy2005 Physician Fee Schedule as its ground to reject psychological testing, emergency department, and observation services. It stated that occupational therapy, physical therapists, and speech-language pathologists are not approved telehealth practitioners. Therefore, those services offered by these specialists couldn’t be added to the list of reimbursement.

Policies of POS Code

POS codes are employed on professional applications to stipulate the site where services were provided. Currently, no POS code specifically for telehealth exists. However, with multiple requests to establish one, CMS has noted that the POS group controls the process and it isn’t dependent on Physician Fee Schedule decision-making. Meanwhile, CMS has suggested adjustments to the current POS policies, to act as guides for future rulemaking. For instance, telehealth providers report the POS code used when the service is rendered from a distant site.

In sum, CMS has shown through the Proposed Rule, its constant support and accommodation of the use of telehealth technologies as a way of rendering health care services.