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AAFP Criticizes CMS on Telemedicine Reimbursement Restrictions

The physician group says limits included in the 2017 Medicare physician fee schedule would hinder providers using store-and-forward, observational care and ED services.

By Eric Wicklund

- The American Association of Family Physicians is taking CMS to task for elements of the 2017 Medicare physician fee schedule that hinder telemedicine reimbursements for store-and-forward, observational care and ED services.

"In light of the growing amount of evidence suggesting the effectiveness of various forms of telehealth services, the AAFP supports revisions to policies that create unnecessary barriers to the responsible and appropriate use of telemedicine services," AAFP Board Chairman Robert Wergin, MD, wrote in a 56-page letter to the Centers for Medicare & Medicare Services earlier this month.

Chief among the complaints is CMS’ requirement that a patient must be in a “telehealth-origination site” to receive reimbursable care. That basically eliminates asynchronous or store-and-forward platforms, even though at least nine states reimburse the technology through their Medicaid programs.

“Both the appropriateness of telemedicine/telehealth services as the modality of treatment, and the appropriateness of an originating site, should be determined by whether standards of care can be met for a given condition and clinical scenario,” Wergin wrote. “Standards of care are impacted by current technology capabilities, but should not be dictated by arbitrary policies or statutes that become antiquated as a result of improvements in technology capabilities.”

“Increasing numbers of state Medicaid programs are reimbursing for store-and-forward technology in response to heightened awareness that improvements in technology are enabling standards of care to be met using telehealth as the modality for service for an increasing number of clinical conditions,” he added. “We urge Medicare to likewise provide reimbursement for use of asynchronous store-and-forward technology.”

Wergin also criticized CMS for its plans to deny new CPT codes related to observation visits and emergency department care.

“A physician is capable of assessing a patient’s physical condition in an observational setting and determining an appropriate course of treatment via telemedicine routes of delivery,” Wergin said. “With the physician shortage issues and increasing lack of ideal access to care that can occur in any geographic region - most especially in rural areas - it is important that these services be allowed to be provided both as in-person or reimbursable telemedicine services.”

“Patients in rural settings should not be denied access to needed observation care due to a lack of inclusion of these codes within the list of Medicare telehealth services,” he said. “Furthermore, telehealth services are an important access point for patients with chronic conditions and multiple comorbidities where in-office visits may be difficult.”

Of CMS’ decision to deny CPT codes 99281, 99282 and 99283, Wergin argued that emergency departments in both rural and urban settings are using telemedicine to help with overcrowding, staff shortages and access to specialty care – especially with regard to stroke treatment.

“Reimbursing physicians and eligible providers appropriately for emergency department care rendered via telehealth services can be critical in any geographic region, especially within rural areas, where primary care physicians may provide emergency department physician coverage using telehealth technologies due to an absence of available emergency department physician coverage otherwise,” he wrote. “It is not appropriate to render those services as ineligible for reimbursement merely because evidence has not yet been submitted to support the clinical benefit of managing emergency department patients with telehealth.”

Dig Deeper:

ATA Lobbies Medicare for More Telehealth Reimbursement

Letter: Telemedicine’s Value to Medicare Has Been Proven


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