Expanding Medicare payment for ‘virtual check-ins’ – will it drive telehealth adoption?

Beginning in January 2019, Medicare patients may have more calls and video chats with their physicians in between office appointments.

That’s because, on July 12, federal regulators overseeing the Medicare program included in a large package of proposed rules a provision that would allow for stand-alone reimbursement for so-called “virtual check-ins.”

Let’s take a look at the details of this provision, which starts on page 63 of the 1,472-page  draft CY 2019 Physician Fee Schedule, released by the Centers for Medicare and Medicaid Services (CMS). The details:

  • The service is called a “brief communication technology-based service“ or a “virtual check-in,“ and is defined as a quick 5-10 minute chat conducted possibly via phone, video or other communications technology between a patient and their physician or “other qualified health professional;“
  • Medicare would pay $14 per virtual visit in 2019, compared to $92 for an in-person office visit;
  • The physician or other clinician on the line already must have an established relationship with the patient to qualify for reimbursement;
  • The check-in can’t originate from a service offered in the past seven days or lead to a procedure in the following 24 hours or soonest available appointment. If these conditions happen, the virtual check-in is bundled into a regular office visit for billing;
  • The check-in could be used for opioid or other substance abuse disorder continuing treatment;
  • There might be a cap on the number of allowable virtual check-ins per patient (The CMS is asking for public input on this point.);
  • Patients could reside anywhere to receive the service, unlike most other telehealth services that Medicare pays for, which largely are restricted by statute to rural beneficiaries;
  • Fewer than one million virtual check-ins are expected to be billed in the first year but will eventually result in 19 million visits annually, according to CMS estimates based on claims data and a study in Health Affairs.

Telehealth advocates applauded the proposal but also expressed skepticism that it would advance telehealth adoption in any meaningful way. Practically, these check-ins are most likely to be done by phone. David Raths of Healthcare Informatics has a deeper dive into industry response.

Also in the CMS’s proposed physician fee schedule for next year is a plan to pay clinicians to evaluate patient-submitted photos. This type of telehealth service, called “store and forward,“ is routinely conducted for dermatology concerns.

It’s worth noting that many health systems are already doing phone check-ins on patients as part of their care transition programs to reduce avoidable readmissions. Technology companies are making these calls less time-consuming for clinicians by initiating robo-calls to patients, and then only connecting to a live nurse if a patient reports an issue or question.  Two vendors in this space are CipherHealth and Emmi Solutions.

It will be interesting to see how this proposed rule evolves after the comment period, and whether local physicians take advantage of this new reimbursement channel to make a quick call or video chat to their Medicare patients.

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