Wrapping up the first period of public commentary, the Centers for Medicare & Medicaid Services (CMS) has revised its official 2023 physician fee schedule “proposed rule,” opening a new period of commentary extending into September. And included in the 2023 CMS fee schedule update is a significant extension of reimbursement guidelines for telehealth services like remote patient monitoring (RPM).
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Every year, changes to the CMS fee schedule are introduced as part of a “proposed rule.” (This year, that first version of the proposal was issued in April.) Several months are then provided for commentary on those rules, after which CMS offers a new, adjusted version. Feedback is solicited again, in preparation for the final version. The changes are then finalized and implemented on January 1 of the following year.
In the wake of Covid-19, these rule changes have been more significant than ever, offering additional methods for providers to receive reimbursement for different types of patient care. As we saw with the new rules that went into effect on January 1, 2022, those changes can open up new opportunities for reimbursement as well as enable altogether new channels for patient care.
For instance, the new remote therapeutic monitoring (RTM) CPT codes introduced in 2022 have been a game changer. For some providers, the new RTM model — as well as the availability of RPM devices like remote spirometers — has empowered them to not only more closely manage certain patients, but boost outcomes among some high-risk individuals, too.
With that in mind, let’s take a look at the proposed updates to the CMS fee schedule for 2023, and how they may affect healthcare providers over the next couple of years.
What’s Changing in the Proposed CMS Fee Schedule for 2023?
The proposed rule for the 2023 CMS physician fee schedule includes a number of important provisions, most of which are updates to existing schedules and methodologies. Chief among them are proposals to:
- Expand reimbursement for managing patients with chronic conditions with new HCPCS codes for chronic pain management and treatment services (CPM)
- Decrease the CY 2023 PFS conversion factor (by $1.53)
- Update the methodology used to estimate the Medicare Economic Index (MEI), and the frequency of updates
- Create a new General Behavior Health Integration (BHI) service to allow the expansion of behavioral health services
- Adjust the Clinical Laboratory Fee Schedule (CLFS), which could include the codifying of new policies around collection fees
- Change the pricing methodology used for Opioid treatment Programs (OTPs)
- Let beneficiaries access audiology services without the need for a physician referral
- Expand coverage for some specific types of colorectal cancer early detection services
- Update the payment amount for preventive vaccine administration under Medicare Part B
However, of all the proposals in the 2023 CMS fee schedule updates, there’s one that’s of immediate interest to those healthcare providers offering remote patient monitoring (RPM) and other telehealth services. The proposed rule seeks to extend the “telehealth provisions” currently resulting from the COVID-19 public health emergency (PHE) for another 151 days after the initial period ends.
According to JD Supra, these special PHE allowances also include “allowing telehealth services to be furnished in any geographic area and in any originating site setting, including the beneficiary’s home.” Though in line with current PHE rules, a permanent change for this guideline would represent a major shift from just a few years ago, when the rules for what constitutes an originating site were more strictly defined.
The proposed rule would also allow “certain services to be furnished via audio-only visits,” the JD Supra report adds. It would also allow “physical therapists, occupational therapists, speech-language pathologists, and audiologists to furnish telehealth services” — a major adjustment that’s certain to open the door to more reimbursement opportunities for more types of providers.
On a related note, he proposed rule could also “delay the in-person visit requirements for mental health services furnished via telehealth until 152 days after the end of the PHE,” the JD Supra report adds.
Proposed 2023 CMS Fee Schedule for 2023 in Line with Legislative Goals for Telehealth Expansion
This move by CMS to continue to expand coverage for telehealth comes amid renewed activity by lawmakers to do the same. As the healthcare industry eases out of the COVID-19 public health emergency, some legislators are seeking to make the use of remote care more permanent.
The United States House of Representatives passed legislation to this effect on July 28, 2022. Officially named “H.R. 4040, Advancing Telehealth Beyond COVID-19 Act of 2022,” the new bill seeks to make permanent the same extensions outlined in the proposed CMS fee schedule for 2023.
The bill would make a few additional adjustments to telehealth reimbursement rules to preserve and expand current “flexibilities,” as Susan Morse writes at Healthcare Finance: “From broadened access to care to removing geographic and originating-site restrictions,” she explains, the legislation follows the lead of the American Medical Association (AMA) in seeking to more permanently codify the PHE rule for telehealth permanent.
What does that mean, exactly? For starters, the bill would allow for “federally qualified health centers and rural health clinics to serve as the distant site, that is, the location of the healthcare practitioner,” Morse explains. It would also “allow beneficiaries to receive telehealth services at any site, regardless of type or location,” she adds, and “would allow any type of practitioner to furnish telehealth services” (subject to CMS approval).
“Increased Medicare-covered access to telehealth has been a lifeline to patients and physicians throughout the COVID-19 pandemic, and the American Medical Association is pleased by today’s bipartisan vote in the House,” AMA President Dr. Jack Resneck Jr. said in a statement released upon news of the House bill’s passage.
“The COVID-19 public health emergency made plain that care via telehealth should be available to all Medicare patients, especially with their own physicians, regardless of where they live or how they access these services,” Resneck added.
The bill now has to pass the United States Senate — no small task! Yet even if the bill fails to win full approval this year, it’s clear that many lawmakers are seeking to expand telehealth access on a long-term basis in the near future.
And as CMS continues to expand its fee schedule to accommodate telehealth services like remote patient monitoring, that means even more opportunities for providers to leverage these important technologies and platforms in the months and years to come.
Seize the Power of RPM & Telehealth with CareSimple
As the 2023 CMS fee schedule seeks to extend reimbursement for telehealth and RPM services, don’t be left behind on these important models for patient care. Learn how CareSimple can help get your organization up to date: Contact us here or schedule a demo to connect with us today!
And if you’re looking for details on reimbursement as outlined in the 2022 CMS fee schedule, you can get the info you’re looking for with the CareSimple Reimbursement Tree.