We are in the comment period, and the final rule will be released in early November.
Just a reminder that all of the new HCPCS and CPT® codes discussed in the rule are “dummy” codes, placeholders for the codes to be released.
In this post: podiatry, brief virtual check-in, inter-professional consultations, and more
Count your pennies
The conversion factor was changed from $35.9996 to $36.0463.
CMS is proposing two new codes to report Podiatry E/M services
- one for new patients
- one for established patients
The new patient visit would pay about $102 in the office and $73 in a facility setting. The established visit would pay $67 in the office and $45 in a facility setting. Podiatrists would use these codes in place of 99201—99215 codes.
Inherent complexity codes
- one for primary care
- one for certain specialist
GPC1X: Visit complexity inherent to evaluation and management associated with primary medical care services that serve as the continuing focal point for all needed health care services (Add-on code, list separately in addition to an evaluation and management visit).
The wRVU for this service is .07. This code has differential payment based on setting, with a payment of about $5.40 in a non-facility, office setting and $3,96 in a facility setting.
GCG0X: Visit complexity inherent to evaluation and management associated with endocrinology, rheumatology, hematology/oncology, urology, neurology, obstetrics/gynecology, allergy/immunology, otolaryngology or interventional pain management-centered care (Add-on code, list separately in addition to an evaluation and management visit).
This add-on code has wRVUs of .25 and a payment of about $13.70, in a facility or non- facility setting.
New prolonged services code, 30 minutes
GPRO1: Prolonged evaluation and management or psychotherapy service(s) (beyond the typical service time of the primary procedure) in the office or other outpatient setting requiring direct pateint contact beyond the usual service; 30 minutes (List separately in addition to code for office or other outpatient Evaluation and Management or psychotherapy service)
This code has wRVUs of 1.17. Payment in a non-facility would be about $67.40 and in a facility $63.80.
CMS heard that using the CPT® codes for prolonged services was difficult, because the prolonged time was 60 minutes. The time for this service is 30 additional minutes.
In order to bill it, the provider would need to meet the threshold of the base code and half of the prolonged code.
New CCM code (Chronic care management)
CPT® has developed a new code for 30 minutes in a calendar month of chronic care management performed by the physician or non-physician practitioner, not staff.
It has a work RVU of 1.22 and pays about $74.25. There is no differentiation between the facility and non-facility rate. The dummy code CMS used in the rule is 994X7, and we’ll see the CPT® code when the AMA releases the CPT® books.
There are existing CPT® codes for inter-professional consults, based on time, that had a status indicator of bundled. That is, CMS did not pay them. These codes, 99446—99449 have been in the CPT® book since 2013.
CMS is proposing to change the status indicator form bundled to active, making them paid services. Since these are existing CPT® codes, you can read about them in your current book.
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
99447 11-20 minutes
99448 21-30 minutes
99449 over 31 minutes
CPT® has developed two additional codes in this series. (Below, are the dummy codes, new CPT® codes in your 2019 book when in arrives).
994X0 Interprofessional telephone/Internet/electronic health record referral service(s) provided by a treating/requesting physician or qualified health care professional, 30 minutes
994X6 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 or more minutes of medical consultative time
Here are two quotes from the rule about the purpose of these services and CMS’s concerns:
“…specialty expertise to assist with the diagnosis and/or management of the patient’s problem without the need for the patient’s face-to-face contact with the consulting physician or other qualified healthcare professional…”
“We note there are program integrity concerns.”
The rule continues that we can’t bill for “professional courtesy or continuing education,” and that these services would require verbal consent from the beneficiary in advance of the service.
Acute stroke telehealth services
The Bipartisan Budget Act of 2018 required CMS to pay for acute stroke telehealth services. CMS is proposing to develop a modifier to report these services. The rule removes the restriction on geographic location for these services only.
Brief virtual check-in
There was a disturbance in the force. You felt it, didn’t you? CMS is proposing to pay for – well—here’s the (dummy HCPCS) code, read it for yourself.
GVCI1: Brief communication technology-based service, e.g., virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.
The non-facility payment would be about $15.40 and the facility payment would be $13.37. Not a lot of money, but isn’t there an expression about getting your nose under the tent?
This would only be allowed for established patients, and only providers with E/M services in their scope of practice could bill it. CMS is seeking comments about requiring verbal consent to bill and frequency limitations.
Here’s a picture of the tick | Remote Services
Haven’t you always wanted to send a picture of that rash or the tick to your provider? Or, have I been reading the rule for too long? Well, now we can do it.
CMS is going to pay your provider almost $13 to look at your picture and reply back to you “verbally.” There is a whopping .18 wRVU for this service, an office payment of about $12.97 and facility payment of $10.09.
GRAS1: Remote pre-recorded service via recorded video and/or images submitted by the patient (e.g, store and forward), including interpretation with verbal follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment.
There’s more to the rule, but these are some of the most interesting parts for medical practices.
Learn more about these and other important proposed changes by watching the on-demand webinar.