Virtual Check-in Rule Creates Provider Efficiency, Reimbursement

CMS has finalized its 2019 proposal to begin reimbursement of two newly defined physicians’ services using technology-based communication.

This article appears in the January/February 2019 edition of HealthLeaders magazine.

CMS’ continued commitment to patient access and acceptance of the role technology plays in the delivery of such patient services is apparent in the 2019 Medicare Physician Fee Schedule final rule. The agency has finalized its proposal to begin reimbursement of two newly defined physicians’ services using communication technology. The ability to utilize and submit these new HCPCS level II codes benefits patients, insurers, and providers through convenience and cost savings.

The two newly defined physicians’ services are:

• Brief communication technology-based service (e.g., virtual check-in) (G2012)
• Remote evaluation of recorded video and/or images submitted by an established patient (G2010)

Although these services resemble telehealth, CMS clearly indicates that the services are not considered Medicare telehealth services; therefore, they are not subject to the geographic and other restrictions on telehealth services under section 1834(m) of the Social Security Act.

The creation and finalization of HCPCS G2012 allows for separate reimbursement of the brief communication technology-based patient check-in with the physician to determine the necessity of an office visit or other service. The ability for the patient to confer with the physician prior to the office visit increases efficiency for healthcare providers and convenience for patients.

For G2012 to be considered a reimbursable service, healthcare providers must meet the following
requirements:

1. Virtual check-in must be reasonable and medically necessary.
2. The service can only be provided to an established patient of the provider.
3. Given that there is a cost-sharing for the beneficiary due to coinsurance, the patient must give verbal consent for the service, and the consent must be documented in the medical record for each time the service is provided.
4. Only a provider who can report an evaluation and management (E/M) service can bill for this service (i.e., communications between patient and clinical staff are not billable).
5. The virtual check-in cannot relate to an E/M service, meaning the communication cannot be related to an E/M visit provided to the patient in the last seven days or result in an E/M visit in the next 24 hours (or soonest available).
6. Modalities permitted include real-time audio-only telephone interactions in addition to synchronous or two-way audio interactions that are enhanced with video or other kinds of data transmission. The final rule clearly stated that communications by email, text, or voicemail (exclusively) will not be reimbursed.

For G2010 to be considered a reimbursable service, healthcare providers must meet the following requirements:

1. The service must be reasonable and medically necessary.
2. The service can only be provided to an established patient of the provider.
3. Given that there is a cost-sharing for the beneficiary due to coinsurance, the patient must give verbal consent for the service, and the consent must be documented in the medical record for each time the service is provided.