December 2, 2020

Yesterday, December 1, the Center for Medicare and Medicaid Services (CMS) finalized the Calendar Year 2021 Physician Fee Schedule (PFS) (Full PDF).

The finalized 2021 PFS confirms the permanent addition of a number of codes that are currently on the Medicare telehealth list as a result of the COVID-19 public health emergency (PHE), and adds other codes provisionally through the end of the year in which the PHE ends.

A few of the new permanent codes (Category 1) added include:
  • Group Psychotherapy (CPT code 90853)
  • Psychological and Neuropsychological Testing (CPT code 96121)
  • Domiciliary, Rest Home, or Custodial Care services, Established patients (CPT codes 99334-99335)
  • Home Visits, Established Patient (CPT codes 99347-99348)
  • Cognitive Assessment and Care Planning Services (CPT code 99483)
  • Visit Complexity Inherent to Certain Office/Outpatient E & M (HCPCS code G2211)
  • Prolonged Services (HCPCS code G2212)

Alongside these permanent code additions, CMS added guidance on some of the temporary codes pertaining to PHE waivers and expansions. They also address a number of other issues, such as limits on frequency for nursing facility visits furnished via telehealth. Clarification was also provided around issues such as the ability of physical, occupational and speech language pathologists to furnish brief online assessment and management services. CMS further specifies that current telehealth restrictions do not apply when a beneficiary and practitioner are in the same location even if conducted via audio/video technology. 

A few of the provisionally added codes (Category 3) include:
  • Domiciliary, Rest Home, or Custodial Care services, Established patients (CPT codes 99336-99337)
  • Home Visits, Established Patient (CPT codes 99349-99350)
  • Emergency Department Visits, Levels 1-5 (CPT codes 99281-99285)
  • Nursing facilities discharge day management (CPT codes 99315-99316)
  • Psychological and Neuropsychological Testing (CPT codes 96130-96133; CPT codes 96136-96139)
  • Therapy Services, Physical and Occupational Therapy, All levels (CPT codes 97161-97168; CPT codes 97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761, 92521-92524, 92507)
  • Hospital discharge day management (CPT codes 99238-99239)
  • Inpatient Neonatal and Pediatric Critical Care, Subsequent (CPT codes 99469, 99472, 99476)
  • Continuing Neonatal Intensive Care Services (CPT codes 99478-99480)
  • Critical Care Services (CPT codes 99291-99292)
  • End-Stage Renal Disease Monthly Capitation Payment codes (CPT codes 90952, 90953, 90956, 90959, 90962)
  • Subsequent Observation and Observation Discharge Day Management (CPT codes 99217; CPT codes 99224-99226)

Audio-only codes, which are currently allowed under the PHE, have been of particular interest to stakeholders, especially for those who serve rural populations, and others who may not have access to devices or adequate internet connectivity for live videoconferencing. While CMS will not continue to recognize audio-only codes once the PHE is lifted, they are establishing a new HCPCS G-code describing 11-20 minutes of medical discussion to determine the necessity of an in-person visit, based on comments received from stakeholders.

Including PFS codes in previous calendar years, CMS has been gradually expanding coverage for what it calls remote physiologic monitoring services (RPM). As mHealthIntelligence describes here, and Foley and Lardner explores here, the agency proposed significant changes in the initial PFS released in August. That coverage is now set in place with the 2021 PFS.

Finally, in yesterday's press release (available here), CMS announced that it will convene a study on telehealth use during the pandemic to “explore new opportunities for services where telehealth and virtual care supervision, and remote monitoring can be used to more efficiently bring care to patients and to enhance program integrity, whether they are being treated in the hospital or at home.”