So, here are some ruminations on the urgent, out of cycle rulemaking CMS released tonight to address outstanding telehealth issues during the COVID PHE. First, it is an interim final rule, so what came out tonight is official policy. @RPANephrology 1/
Second, it seems to remove any doubt that all ESRD MCP interactions can be provided by telehealth. Not that nephrologists shouldn’t see their patients when safe for all to do so, it’s just that telehealth can be used and billed for when that’s not that case. @RPANephrology 2/
One note, CPT code 90956, for single visit monthly services provided to patients 2-11 years old, was not included on the list with all of the other outpatient dialysis codes. CMS is aware of the oversight. @RPANephrology 3/
More happy news is that CPT codes 99441-99443 for telephone E&M services, are now payable. The unadjusted payment for 441 is about $14.40 (5-10 mins) for 442 is about $28.80 (11-20 mins) and for 443 is about $41.04 (21-30 mins). @RPANephrology
Also, requirements around patient consent were substantially eased for the duration of the public health emergency (PHE), as well as state licensure restrictions for Part B providers. @RPANephrology 5/
And as my friend @signaturedoc points out, the changes are retroactive to 3/1, so if you have your billing and coding ducks in a row, you can bill for that period (and if you don’t, check out RPA’s online Billing and Coding seminar). That’s all for now. @RPANephrology 6/end.
One addendum to this thread: if I’m reading the interim final rule correctly, as of this rule CMS is creating a new modifier, modifier -95, for use on telehealth claims submitted during the PHE. @RPANephrology 7/really the end
