Skilled Nursing Facility (SNF) Telehealth Services

November 12, 2010— Newly added Frequently Asked Question on Telehealth

Question: Will Medicare Part B pay for initial and subsequent nursing facility visits furnished by telehealth?

Answer: Effective January 1, 2011, the Centers for Medicare & Medicaid Services approved the addition of subsequent nursing facility care services (99307–99310) to the list of Medicare telehealth services with the limitation of one telehealth subsequent nursing facility care service every 30 days. The initial visit and Federally-mandated periodic visits [as defined by 42 CFR §483.40(c)] should be conducted in-person. It may not be furnished through telehealth. Medicare beneficiaries are eligible for telehealth services only if they are in an originating site (skilled nursing facilities are an authorized originating site) located in a rural health professional shortage area or in a county outside of a Metropolitan Statistical Area.

As a condition of payment, an interactive audio and video telecommunications system must be used that permits real-time communication between a physician or practitioner at the distant site and the beneficiary at the originating site.

Background

Section 149 of Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) added hospital-based or critical access hospital-based renal dialysis centers, skilled nursing facilities, and community mental health centers to the list of entities that may act as originating sites for payment of telehealth services, effective January 1, 2009. The Centers for Medicare & Medicaid Services noted in its Physician Fee Schedule Final Rule that since MIPPA does not change the existing eligibility criteria for payment and billing requirements related to telehealth services, it is adopting policies similar to existing policies with respect to provision of and payment for telehealth services in these additional originating sites. CMS is doing so on an interim final basis and will respond to any comments and finalize policies in subsequent rulemaking. CMS also announced that the CY 2009 originating site facility fee is $23.72.

More specifically, services provided by distant site physicians or practitioners are only paid for via telehealth if such services are not included in a bundled payment to the facility that serves as an originating site. The telehealth originating site facility fee is a separately billable Part B payment that is payable outside any other payment methodology. Renal dialysis centers, the community mental health centers and SNFs are all paid based upon different payment systems. Therefore, for example, when a SNF is the originating site for Medicare telehealth services, it can receive separate payment for a telehealth originating site facility fee in addition to a bundled per diem payment under the SNF PPS for a resident’s covered Part A stay. Also, not only would the originating site facility fee be separately billable outside of the SNF PPS, but so would those professional services (furnished at the distant site) that meet criteria specified in section 1834(m)(2)(A) of the Act for payment as telehealth services.

However, payment for the services of clinical social workers, registered dieticians, and nutritional specialists may not be paid for under the telehealth benefit as these services are bundled in the SNF/PPS. There are similar restrictions for professional services furnished via telehealth if the services are included in the composite rate or the monthly capitation rate for physician services payable to ESRD facilities.

Eligibility Requirements

According to Medicare Claims Processing Manual Chapter 12 Section 190.2, Medicare beneficiaries are eligible for telehealth services only if they are presented from an originating site located in either a rural health professional shortage area (HPSA) as defined by §332(a)(1) (A) of the Public Health Services Act or in a county outside of an MSA as defined by §1886(d)(2)(D) of the Act.

Entities participating in a Federal telemedicine demonstration project that were approved by or were receiving funding from the Secretary of Health and Human Services as of December 31, 2000, qualify as originating sites regardless of geographic location. Such entities are not required to be in a rural HPSA or non-MSA.

Eligible Telehealth Services

According to Medicare Claims Processing Manual Chapter 12 Section 190.3, eligible services include:

• Consultations (CPT codes 99241 - 99255) - Effective January 1, 2006;
• Office or other outpatient visits (CPT codes 99201 - 99215);
• Individual psychotherapy (CPT codes 90804 - 90809);
• Pharmacologic management (CPT code 90862);
• Psychiatric diagnostic interview examination (CPT code 90801) – Effective March 1, 2003;
• End Stage Renal Disease (ESRD) related services (HCPCS codes G0308, G0309, G0311, G0312, G0314, G0315, G0317, and G0318) – Effective January 1, 2005;
• Individual Medical Nutrition Therapy (HCPCS codes G0270, 97802, and 97803) - Effective January 1, 2006;
• Neurobehavioral status exam (CPT code 96116) - Effective January 1, 2008; and
• Follow-up inpatient telehealth consultations (HCPCS codes G0406, G0407, and G0408) - Effective January 1, 2009.

The use of a telecommunications system may substitute for a face-to-face, “hands on” encounter for these services. Additional services will be added through the rulemaking process.  See the CMS website link below for more information.

Important Links

CMS Web site
Medicare Claims Processing Manual Chapter 12 Sections 190-190.7
Medicare Claims Processing Manual Chapter 15 Sections 270-270.5.1
Change Request 6215