Original Source: Center for Connected Health Policy
Medi-Cal Telehealth Fee-For-Service Policy Update
On July 29, 2019, the California Department of Health Care Services (DHCS) which oversees the state’s Medicaid program (Medi-Cal), released their final telehealth policy update for fee-for-service. In October 2018, DHCS released proposed changes to telehealth policies for Medi-Cal fee-for-service, Federally Qualified Health Centers (FQHCs), Rural Health Clinics (RHCs), Indian Health Services (IHS) and Family Planning, Access, Care and Treatment (FPACT). A copy of the final fee-for-service policy is available on the DHCS website though it is still labeled “DRAFT.” The Department states that while this is the final policy, the official version of the policy will be published on their site later this month along with the updated manuals for FQHCs, RHCs, IHS, and FPACT. When all manuals have been released, CCHP will do an in-depth analysis of all of the new policies. In the meantime, CCHP has created a side-by-side comparison of Medi-Cal’s previous policy, the October 2018 proposal and the final proposal as well as highlighting some of the changes in the final policy.
CCHP will also be holding an informational webinar in the Fall to go over these exciting changes in Medi-Cal’s policies. Stay tuned for more information.
CCHP Releases Factsheet on Telehealth Components of Proposed Physician Fee Schedule
The Center for Medicare and Medicaid Services (CMS) has released their proposed Medicare Physician Fee Schedule (PFS) for CY 2020. Comments on the proposals are due no later than 5 pm on September 27, 2019. The proposal includes the addition of three new codes for a bundled episode of care for treatment of opioid use disorder to the list of services that are eligible for telehealth reimbursement. These codes include:
- HCPCS code GYYY1: Office-based treatment for opioid use disorder, including development of the treatment plan, care coordination, individual therapy and group therapy and counseling; at least 70 minutes in the first calendar month.
- HCPCS code GYYY2: Office-based treatment for opioid use disorder, including care coordination, individual therapy and group therapy and counseling; at least 60 minutes in a subsequent calendar month.
- HCPCS code GYYY3: Office-based treatment for opioid use disorder, including care coordination, individual therapy and group therapy and counseling; each additional 30 minutes beyond the first 120 minutes (List separately in addition to code for primary procedure).
In accordance with the SUPPORT Act, which created an exception from the Medicare geographic and facility requirement for substance use disorder (SUD) treatment or co-occurring mental health disorders, CMS is allowing these services to be delivered at any telehealth originating site, including the patient’s home without regard for the geographic requirement.
Additionally, CMS is proposing a bundled payment structure for opioid use disorder (OUD) treatment by opioid treatment programs (OTPs), which would include the administration of medication used in medication assisted treatment (MAT), as well as counseling, individual and group therapy and toxicology testing. There would be different payment methodologies for the drug and non-drug components of the bundled payment. Under the proposed rule, CMS would allow the counseling and therapy components to be delivered via live interactive video.
CMS is also taking steps to further refine the codes for transitional care management (TCM) and chronic care management (CCM), and create new codes for principal care management (PCM) services for patients that have only one serious chronic condition. The new codes include the following:
- HCPCS code GPPP1 – Comprehensive care management services for a single high-risk disease, e.g., Principal Care Management, at least 30 minutes of physician or other qualified health care professional time per calendar month with the following elements: One complex chronic condition lasting at least 3 months, which is the focus of the care plan, the condition is of sufficient severity to place patient at risk of hospitalization or have been the cause of a recent hospitalization, the condition requires development or revision of disease-specific care plan, the condition requires frequent adjustments in the medication regimen, and/or the management of the condition is unusually complex due to comorbidities.
- HCPCS code GPPP2 – Comprehensive care management for a single high-risk disease services, e.g. Principal Care Management, at least 30 minutes of clinical staff time directed by a physician or other qualified health care professional, per calendar month with the following elements: one complex chronic condition lasting at least 3 months, which is the focus of the care plan, the condition is of sufficient severity to place patient at risk of hospitalization or have been cause of a recent hospitalization, the condition requires development or revision of disease-specific care plan, the condition requires frequent adjustments in the medication regimen, and/or the management of the condition is unusually complex due to comorbidities.
Finally, CMS is requesting comments on consent requirements for technology-based communication services, after receiving feedback from practitioners that obtaining consent for each and every communication technology-based service is burdensome. CMS is considering the possibility of obtaining advance consent for a number of communication technology-based services.