Grassi Healthcare | EAlert: Important Updates in BH and Telehealth
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EAlert: Important Updates in BH and Telehealth

03/16/2018
Important Updates in the 2018 CMS Final Rule for Physician and Behavioral Health Services!

IMPORTANT UPDATE #1:The Rule Shows Improvement of Payment Rates for Non-facility and Office-based Behavioral Health Services.

CMS is in the process of finalizing an improvement in the way Medicare Physician Fee Schedule (MPFS) rates are set that will positively impact office-based behavioral health services.
 
The Final Rule Includes an Adjustment to Allocation of Indirect PE for Some Office-Based Services.
 
Stakeholders have suggested that for codes in which direct Practice Expense (PE) inputs for a service are very low, the current allocation methodology does not allow for a site of service differential that appropriately reflects the relative indirect costs for furnishing services in non-facility settings. When looking at the services most affected by this, primary therapy and counseling services for treatment of behavioral health conditions, including substance use disorders, were identified. For example, when looking at the most commonly billed psychotherapy service (CPT code 90834), the difference between the non-facility and facility PE RVUs is only 0.02 RVUs. The variance seemed unlikely to represent the difference related to administrative labor, office expense, and all other expenses incurred by the billing practitioner for 45 minutes of psychotherapy services when furnished in the office or other non-facility settings vs. the facility setting.
 
CMS then made a determination of what codes used in the non-facility settings were below the bar of 0.4 PE RVU’s. Fewer than 50 codes were identified for a potential change in the indirect PE allocation method, most of which are primarily furnished by behavioral health professionals. CMS needed to identify an appropriate PE for these services and targeted the most commonly billed physician visit, CPT code 99213, which is billed by a wide range of physicians and non- physician practitioners under the MPFS. They thought it likely that the PE costs related to providing 99213 would equate to the behavioral health services identified as needing PE modification whilst acknowledging behavioral health professionals may be unlikely to incur some of these costs (such as separate office and examination room space, and storage for disposable medical supplies), however other costs (such as staff and records storage & maintenance), would not vary. They moved ahead with this understanding and utilized this, a ratio and other influencing factors as the baseline for the reasonable minimum allocation. The CMS proposed approach estimates approximately $40 million, or approximately 0.04 percent of total PFS allowed charges, would shift within the PE methodology for each year of the proposed 4-year transition, including for CY 2018. CMS considered comments made and then moved ahead with the proposed changes in the Final Rule.
 
In addition, many managed care contracts are based on a percentage of Medicare so the increase will flow thru to these contract rates as well—creating an overall increase and a better compensation schedule for these sorely needed professionals!
 
Good News for Behavioral Health Providers!
 
IMPORTANT UPDATE #2: Telehealth Also Sees Some Changes with Additional Codes and a Reduction to the Administrative Burden
 
Telehealth providers are aware that the fee for CPT code Q3014 Telehealth originating site facility fee has a mandated annual increase based on the Medicare Economic Index (MEI) beginning January 1, 2003. The MEI increase for 2017 is 1.2 percent—making the originating site fee 80 percent of the lesser of the actual charge, or $25.76. The Medicare beneficiary is responsible for any unmet deductible amount and Medicare coinsurance for this service.
In addition, CMS added a number of services to the Telehealth array of allowable services.

They include: 
  • G0296 - Counseling visit to discuss need for lung cancer screening (LDCT) using low dose CT
  • 90785 – Psychiatric/psychological services Interactive Complexity
  • 96160 - Administration of patient-focused health risk assessment instrument and
  • 96161 - Administration of care-giver-focused health risk assessment instrument
  • G0506 - Comprehensive assessment of and care planning, pts requiring CCM services (add-on)
  • 90839 - Psychotherapy for Crisis, initial 60 min.
  • 90840 - Psychotherapy for Crisis, ea. additional 30 min.
 
CMS is also finishing up the separate payment for CPT code 99091 - Collection and interpretation of physiologic data, which describes certain remote patient monitoring. The code is payable in both non-facility and facility settings.
 
CMS has also eliminated the modifier telehealth modifier GT for professional claims in an effort to reduce administrative burden for practitioners. Using POS 02 provides the same Telehealth attestation as the modifier GT previously did.