Under a rule proposed by the Centers for Medicare and Medicaid Services (CMS) on July 8, Medicare Part B payments to medical practitioners would be allowed for non-face-to-face care for some patients if certain conditions are met. This is in contrast to the current physician fee schedule (PFS) policy, which does not allow separate payments for non-face-to-face evaluation and management (E/M) services. The non-face-to-face care management work is considered in calculating the relative value units (RVUs) for E/M services. “However, the physician community continues to tell us that the care management included in many of the E/M services, such as office visits, does not adequately describe the typical non-face-to-face care management work for certain categories of beneficiaries,” CMS said in the proposed rule.

Under the proposed rule, payments would be allowed for qualifying non-face-to-face care provided to Medicare beneficiaries who have multiple (two or more) complex chronic conditions that are expected to last at least 12 months or until the death of the patient, and that place the patient at significant risk of death, acute exacerbation/decompensation, or functional decline. In addition, the Medicare beneficiary must have had, within the last 12 months, an annual wellness visit or an initial preventive physical examination (GO402), if applicable.