CMS Revises Telehealth
By Sandra Hernandez, MSMIS, RHIA, CCS, CPHI, CHC
THE CENTERS FOR Medicare and Medicaid Services (CMS)
has continued its efforts to reduce the administrative burden
for physicians and “restore the doctor-patient relationship” by
easing reimbursement requirements for telemedicine services. 1
In 2019, CMS established a new interpretation of the applicability of statutory requirements for reimbursement of remote
communication technology, separating it from telehealth services delivered under section 1834(m) of the Social Security Act.
The Calendar Year (CY) 2019 Medicare Physician Fee Schedule
(MPFS) Final Rule expands Medicare-covered telehealth services that will give beneficiaries improved access to care while
potentially lowering out-of-pocket costs. The measure is also
aimed at reducing costs of the program. In April, CMS Administrator Seema Verma announced finalization of this policy, expanding the new telehealth benefits to Medicare Advantage enrollees and allowing these services to be offered outside of the
plan’s supplemental benefits.
Telehealth Payment Rules
Under section 1834(m), payment for telehealth services under
Medicare must meet certain requirements, including type of
telehealth service, qualifying physician or practitioner, originating site where the patient is located, distant site of the provider,
and technology utilized.
Under the new interpretation, services deemed as “telehealth
services” are professional consultations, office visits, and office
psychiatry services. Essentially, any evaluation and management services typically furnished in a face-to-face encounter
and reported with codes 99241-99275 (consultations), 99201-
99215 (office visits), and psychiatric services reportable with
codes 90832-90838 and 90863 are eligible.
For reimbursement purposes, these telehealth services must
be delivered using technology that enables “live” interaction,
such as live video conferencing facilitating two-way audio and
Currently, Alaska and Hawaii participate in a federal telemedicine demonstration program that exempts them from this
requirement. These two states may receive payments for telehealth services that use store-and-forward technologies which
provide for asynchronous transmission of health information in
single or multimedia formats. Store-and-forward technology is
a method of collecting and sending clinical information electronically to another site for evaluation, including diagnostic
reports, images, and video or sound files.
CMS defines an originating site as the “location where a Medicare beneficiary gets physician or practitioner services through
a telecommunications system.” In order to qualify for telehealth
services under Medicare, the beneficiary must be present in
an originating site located in either a rural health professional
shortage area (HPSA) or a county outside a metropolitan statistical area (MSA) when the telehealth service is furnished. An
originating site is technically a facility identified by CMS where
a patient must be present when a telehealth service is furnished
(e.g., a doctor’s office or a hospital).
2019 Final Rule Changes
In its 2019 Final Rule, CMS recognized growing public concern
that existing requirements under section 1834(m) pose “
limitations on appropriate payment for evolving physicians’ services
that are inherently furnished via communication technology, especially as technology and its uses have evolved in the decades
since the Medicare telehealth services statutory provision was