As of January 1st, of this year, CMS implemented the Quality Payment Program (QPP) under MACRA. The QPP offers two payment tracks to eligible clinicians to choose from, MIPS and APMs. Under MIPS, clinicians must follow the guidelines required by four categories. Those categories are Quality, Cost, Improvement Activities, and Advancing Care Information. For the purposes of explaining how Telehealth specifically relates to MACRA and the QPP, we’re going to take a closer look at the Improvement Activities Category and how implementing Telehealth to your practice can help you be successful.
For the first performance year under MACRA, 2017, eligible clinicians reporting under the MIPS payment track will report up to four improvement activities for a minimum of 90 days. Those practices with fewer than 15 participants or those in a rural or health professional shortage areas will attest up to 2 activities for a minimum of 90 days.
If you visit the Improvement Activities page of the CMS QPP Website, you can search the activities using the keyword “telehealth.” Two activities relating to telehealth will appear. Those are:
- Anticoagulant management improvements; and
- Use of telehealth services that expand practice access
While the first activity is more specialty specific, the second one is available to a much larger pool of eligible clinicians. Let’s take a look at the use of telehealth services that expand practice access more closely.
The Use of telehealth services that expand practice access is defined as Use of telehealth services and analysis of data for quality improvement, such as participation in remote specialty care consults or teleaudiology pilots that assess the ability to still deliver quality care to patients. You can view information such as the ID, Subcategory Name, and Weighting by clicking here and searching the activities with the keyword “telehealth.”
Because this activity is considered a medium weighted activity it will contribute 10 points to your score under the Improvement Activities category. More importantly, for most of us, the question is will CMS reimburse for telehealth visits and will the effort be worthwhile?
The good news is that CMS will reimburse for telehealth and they do now consider telehealth a patient-facing encounter. Currently, there are 87 billing codes relating to telehealth visits. Some of the categories include Behavioral Health, End Stage Renal Disease, Medical Nutrition, Regular Office Visits, Subsequent Hospital Care, Nursing Facility Care, Transitional Care, Diabetes Management, Alcohol / Substance Abuse, and more. You can find the entire list of Billing Codes for Telehealth located here: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.html.
There are a few steps you’ll need to take before you get started to ensure you will be reimbursed correctly. Basically, Medicare has set up a few conditions that must be met for them to reimburse you under the Physician Fee Schedule. The service must be on the list of medicare telehealth services which we linked to above. If it is on that list, it must all meet all of the following additional requirements:
- The service must be furnished via an interactive telecommunications system.
- The service must be furnished by a physician or other authorized practitioner.
- The service must be furnished to an eligible telehealth individual.
- The individual receiving the service must be located in a telehealth originating site.
Only after all of these conditions are met, will Medicare pay a facility fee to the originating site and makes a separate payment to the distant site practitioner furnishing the service.
In general, telehealth services are supposed to be furnished via an interactive telecommunications system, which is defined as multimedia communications equipment that includes, at a minimum, audio and video equipment permitting two-way, real-time interactive communication between the patient and distant site physician or practitioner. Based on this definition, telephones, facsimile machines, and stand-alone electronic mail systems do not meet the definition of an interactive telecommunications system.
To learn more about how telehealth services will contribute to your practice and how to implement it, attend our upcoming webinar. Click here to register for the date that works best for you: View Webinar Dates.