CMS Proposes New "Virtual Check-In" and "Remote Evaluation" Benefit for RHCs

CMS released their thousand-plus page 2019 Physician Fee Schedule proposed rule. One major takeaway for RHCs is the proposal of a new “virtual check-in” service.

Nathan Baugh, Director of Government Affairs

CMS Proposes New “Virtual Check-In” and “Remote Evaluation” Benefit for RHCs

Despite the fact that Rural Health Clinics are not paid under the physician fee schedule, significant updates and changes for the RHC program are often included in the Physician Fee Schedule rulemaking process. Yesterday, CMS released their thousand-plus page 2019 Physician Fee Schedule proposed rule. One major takeaway for RHCs is the proposal of a new “virtual check-in” service. CMS describes this as a service where “a physician or non-physician practitioner has a brief (5 to 10 minutes), non-face-to-face check in with a patient via communication technology to assess whether the patient’s condition necessitates an office visit.”

This new “virtual check-in” benefit is the latest non-face-to-face service adopted by Medicare as it seeks ways to lower cost and improve access to health care through technology. CMS states that they “now recognize that advances in communication technology have changed patients’ and practitioners’ expectations regarding the quantity and quality of information that can be conveyed via communication technology.” This service can only be billed when “medical discussion or remote evaluation is for a condition not related to an RHC or FQHC service provided within the previous 7 days, and does not lead to an RHC or FQHC service within the next 24 hours or at the soonest available appointment, since in those situation the services are already paid as part of the RHC or FQHC per-visit payment.”

Additionally, CMS proposes to pay practitioners for a similar “remote evaluation service” which CMS describes as the remote evaluation of patient-transmitted information conducted via pre-recorded ‘store and forward’ video or image technology, including interpretation with verbal follow-up with the patient within 24 business hours.” Like the virtual check-in, this service could not originate from a related E/M service provided in the previous 7 days or lead to an E/M service in the next 24 hours.

Similar to the chronic care management benefit, RHCs will have a different billing mechanism than their fee-for-service peers. CMS is proposing to create a specific RHC G-code with a payment rate that is the average of the two new G-codes available on the fee-for-service side. CMS considered proposing paying for this “virtual check-in” via the all-inclusive-rate but opted for this “combined G-code” methodology instead because they felt that this service would not meet the requirements of an RHC billable visit. It is not yet clear how much that average payment will be.

While it may be reasonable to assume that the cost-reporting implications of providing this service are similar to how we handle care management services, CMS did not specify in this proposed rule those details. NARHC will be sure to work with CMS to get clarification on these new benefits before 2019.

Nathan Baugh
202-544-1880
nathan.baugh@narhc.org