Due to the pandemic, CMS has been forced to adopt modern healthcare policies regarding telehealth. A total of 154 new telehealth CPT codes have been added to address patient needs while they shelter in place. Despite the overwhelming success, the CMS telehealth policy changes are set to revert by the end of the pandemic. However, CMS has recently proposed a new rule that details their future plans regarding some of these new CPT codes.
In this article, we will discuss which CPT codes are staying, which CPT codes are going, and which CPT codes are still under examination.
Which CPT Codes Will CMS Permanently Add?
The clear and unquestionable success of various emergency CPT codes has prompted CMS to propose their permanent inclusion under their list of covered telehealth services. The recent CMS rulemaking has identified 9 CPT codes, which are believed to survive the pandemic:
- Care Planning for Patients with Cognitive Impairment (99483)
- Domiciliary, Rest Home, or Custodial Care services (99334-99335)
- Group Psychotherapy (90853)
- Home Visits (99347- 99348)
- Neurobehavioral Status Exam (96121)
- Prolonged Services (99XXX)
- Visit Complexity Associated with Certain Office/Outpatient E/Ms (GPC1X)
Which CPT Codes Will CMS Temporarily Retain?
CMS has added 13 CPT codes under “Category 3.” This new category contains CPT codes which CMS believes have the potential to be made permanent if they are proven to provide clinical benefit.
Every CPT code under Category 3 would remain until the end of whichever year the pandemic is officially declared to be over. Below are the CPT codes CMS intends to temporarily keep post-pandemic:
- Domiciliary, Rest Home, or Custodial Care Services, Established Patients (99336-99337)
- Emergency Department Visits Levels 1-3 (99281-99283)
- Home Visits Established Patients (99349-99350)
- Nursing facilities discharge day management (99315-99316)
- Psychological and Neuropsychological Testing (96130-96133)
Which CPT Codes Will CMS Discard?
Despite the push to increase the services doctors can provide through telehealth, CMS currently plans to eliminate the majority of the newly added CPT codes.
This list details the 78 CPT codes CMS plans to phase out:
- Critical Care Services (99291-99292)
- Domiciliary, Rest Home, or Custodial Care Services, New Patients (99324-99328)
- End Stage Renal Disease (ESRD) Services (90952-90953, 90956, 90959, 90962)
- Emergency Department Visits Levels 4-5 (99284-99285)
- Home Visits, New Patients, All Levels (99341-99345)
- Inpatient and Neonatal and Pediatric Critical Care (99468-99469, 99471-99473, 99475)
- Initial and Continuing Neonatal Intensive Care Services (99477-99480)
- Initial and Subsequent Observation and Observation Discharge Day Management (99217-99220, 99224-99226, 99234-99236)
- Initial Hospital Care and Hospital Discharge Day Management (99221-99223, 99238-99239)
- Initial Nursing Facility Visits All Levels (99304-99306)
- Psychological and Neuropsychological Testing (96136-96139)
- Radiation Treatment Management Service (77427)
- Therapy Services Physical and Occupational Therapy All Levels (92521-92524, 92507, 97161-97168, 97110, 97112, 97116, 97535, 97750, 97755, 97760-97761)
Which CPT Codes has CMS Left Unclear?
CMS released new CPT codes in three waves during the pandemic. The CPT codes released in March 2020 have been addressed under the proposed rulemaking; however, the future of many CPT codes announced in April and October 2020 has remained unclear.
This is a list of all the new CPT codes that CMS has not mentioned in their latest rulemaking:
- Group Psychophysiological therapy (90875 (Non-Covered Service))
- Eye Exam New And Established Patients (92002, 92004, 92012, 92014)
- Cochlear Implant Management (92601-92604)
- Cardiac Rehabilitation Services (93797-93798)
- Interrogation of Ventricular Assist Device (93750)
- Vent Management (92508, 94002-94005, 94005 (Bundled Code))
- Analysis of Neurostimulator Pulse Generator System (95970, 9597-95972, 95983-95984)
- Developmental Testing (96110, 96112(Non-Covered Service), 96113)
- Health Behavior Intervention Services (96158, 96170-96171 (Non-Covered Service))
- Behavior Identification Assessment (97151-97152, 0362T)
- Adaptive Behavior Treatment (97153-97158, 0373T)
- Telephone evaluation and management service (99441-99443)
- Intensive Cardiac Rehabilitation (G0422, G0423)
- Brief Emotional/Behavioral Assessment (96127)
- Speech/Hearing Therapy (92508)
- Evaluation of Use of Inhaler (94664)
- Group Therapeutic Procedures (97150)
- Therapeutic Activities (97530)
- Wheelchair Management Training (97542)
- Observation or Inpatient Hospital care (99235)
- Pediatric Critical Care (99476)
- Speech Therapy Re-Evaluation (S9152, (not valid for medicare purposes))
- Group Psychotherapy Partial Hospitalization (G0410, statutory exclusion)
- Pulmonary Rehabilitation (G0424)
- Acute Nursing Facility Care (G9685)
At this point, out of the 154 new telehealth CPT codes recently added, only 20 are set to survive past the pandemic.
Physicians want to increase the number and scope of services they can provide through telehealth; however, these plans may be dramatically limited in a post-pandemic world.
Although these services will be covered for now, medical practitioners should prepare for impending CPT codes changes.