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    New CMS Proposed Rule Expands Medicare Reimbursement For Telehealth Services

    Ned Milenkovich, PharmD, JDThe Centers for Medicare and Medicaid Services (CMS) has once again released its Physician Fee Schedule Proposed Rule for Calendar Year 2017 (the Proposed Rule). As part of the release, CMS received multiple requests from stakeholders to establish Place of Service (POS) codes identifying telehealth. CMS responded by including an expanded list of telehealth services that are eligible for Medicare reimbursement in its Proposed Rule.

    Impact On Pharmacy

    The new physician fee schedule provides for expanded reimbursements for treatments that are rendered via telehealth. This is an evolutionary trend. Previously, not only were practitioners not reimbursed, but it was deemed to be illegal to treat a patient in this way.  As a result, prescriptions that were written for and dispensed were not deemed to be legitimate. Now that laws are changing in the various states and telemedicine is becoming much more accepted, pharmacists can be assured that the prescriptions written are acceptable, can be dispensed for a legitimate patient purpose and can be reimbursed properly for the drug dispensed. Currently, only select providers are being reimbursed for treatment under the telehealth model. In the future, a more expansive reimbursement model might include other health care practitioners.

    Medicare Telehealth Services, Reimbursement and the Legal Landscape

    Telehealth is one of the fastest growing sectors in healthcare due to increased pressure to improve efficiency and the desire to reduce health care costs. As a result, the list of covered telehealth and telemedicine services continues to grow. Section 1834(m) of the Social Security Act provides Medicare the authority to reimburse providers for telehealth services under the Proposed Rule.

    To be eligible for reimbursement, the services must be:

    • On the list of Medicare telehealth services;

    • Furnished via telecommunication systems provided by authorized physicians or practitioners; and

    • Provided at an approved “originating site” to an eligible telehealth individual

    The Proposed Rule would add the following telehealth services beginning on January 1, 2017:

    • End Stage Renal Disease (ESRD)-related services;

    • Advance care planning;

    • Telehealth consultations for a patient who requires critical care services

    Ned Milenkovich, PharmD, JD
    This article is not intended as legal advice and should not be used as such. When legal questions arise, pharmacists should consult with ...

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