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    New CMS Proposed Rule Expands Medicare Reimbursement For Telehealth Services


    While these services are slated to be included, CMS also received requests to add services to the telehealth list that it determined did not meet CMS’s criteria for reimbursable telehealth services. CMS rejected the addition of observation codes; emergency department services; psychological testing; and physical therapy, occupational therapy and speech-language pathology services. CMS explained that a lack of evidence supporting the notion that these services are as effective when provided via telecommunication versus in a more traditional setting was the basis for rejecting these additional services.

    CMS also rejected inclusion of physical therapy, occupational therapy and speech-language pathology services citing the definition of authorized practitioners in Section 1834(m) of the Social Security Act. Physical therapists, occupational therapists and speech language pathologists are not currently on the list of authorized practitioners and therefore services provided by these practitioners should not be added to the list of approved telehealth services, according to CMS.

    Place of Service (POS) Codes

    CMS also received multiple requests to establish POS codes specifically for telehealth services. In response, CMS explained that POS work groups within CMS manage the establishment of POS codes and that such a process is not contingent on Physician Fee Schedule rulemaking.   However, CMS is proposing how a POS code specifically for telehealth services would be used under the Physician Fee Schedule to the extent they would become available. The proposition is that physicians or practitioners furnishing telehealth services would be required to report the telehealth POS code to indicate that the billed service is furnished as a telehealth service from a distant site.

    CMS is also proposing to use the facility practice expense relative value units to pay for reported telehealth services. Lastly, to receive the correct reimbursement rate, CMS proposes that the originating site continue to bill for the facility fee and continue to use the POS code for the patient’s location, whether it be facility or non-facility.

    The comment period for the Proposed Rule ran through September 6, 2016.

    Ned Milenkovich is chair of the healthcare law practice at Much Shelist PC and vice chair of the Illinois State Board of Pharmacy. Call him at 312-521-2482 or [email protected].


    Key Points for Pharmacists

    - Prescriptions written are acceptable

    - Prescriptions can be dispensed for a legitimate patient purpose

    - The pharmacy can be reimbursed properly for the drug dispensed

    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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