With the CMS Physician Fee Schedule issuance, details and takeaways are now available. Notably, consistent with our advocacy over the last few years urging CMS to make remote therapeutic monitoring (RTM) available under general supervision, CMS has pulled back on its proposal to replace existing CPT codes for remote therapeutic monitoring with their own HCPCS codes and is now making existing CPT codes for remote therapeutic monitoring possible under general supervision, making RTM far more accessible. This is a very positive development for our community and demonstrates that CHI’s focus on coding and payment has made a big difference! Across the areas below, and others, you can see in the rule that CMS is carefully considering our views.

Overall, the takeaways we’re pulling from the rule so far include the below:

  • Remote Therapeutic Monitoring:
    • CMS has pulled back its proposal to (1) create four new HCPCS G codes for RTM and (2) make existing RTM CPT codes (98980 and 98981) non-payable.
    • Instead, CMS is now permitting general supervision for all RTM codes (98975, 98976, 98977, 98980, and 98981).
    • CMS is adopting the RUC recommendation of contractor pricing for cognitive behavioral therapy CPT code 98978, and will work with MACs to improve understanding.
  • Care Management Codes for Chronic Pain Management (CPM) and General Behavioral Health Integration (GBHI): CMS finalized its proposal for new support for CPM (HCPCS codes G3002 and G3003) and GBHI (HCPCS code G0323).
    • CMS has clarified that CPM HCPCS codes may be billed for the same patient/in same month as RPM and RTM (when reasonable and necessary).
  • Medicare Telehealth Services: CMS found that none of the requests received met its Category 1 or Category 2 criteria for permanent addition to the Medicare Telehealth Services List, but did add some to the Category 3 list (services CMS temporarily includes on the Medicare Telehealth Services List on a Category 3 basis will continue to be included through the end of CY 2023, and CMS will revisit this policy should the PHE be extended “well into” CY 2023).
  • Virtual Presence/Supervision:CMS is not making the virtual presence/supervisions PHE allowances permanent at this time. CMS states that it expects to continue to permit direct supervision through virtual presence through at least the end of CY 2023 under its previously finalized policy which continues through the end of the calendar year in which the PHE ends.
  • Artificial Intelligence: CMS commits to continued engagement on AI and related policy proposals for PFS support of AI use.Read our comment letter here.