Executive Summary
- Medicare is currently reimbursing "virtual sessions" of CR/ICR/PR, delivered via synchronous, real-time audio-video. They are reimbursing at the same rate, and using the same CPT codes as onsite sessions.
- This reimbursement is currently tied to the Public Health Emergency (PHE), which is set to expire on May 11th, 2023.
- However, legislation has now been introduced in the U.S. Congress (HR 1406) that would make reimbursement of virtual sessions permanent, and also permanently allow for virtual direct supervision.
- If this bill passes before May 11th, there will be no gap in reimbursement. We continue to monitor the bill's progress and will post updates here on this page, as we get them.
Background
Updated 3/8/23: In response to the pandemic, the Centers for Medicare & Medicaid Services (CMS) made several temporary changes to reimbursement policies to ensure that patients could continue to access necessary care while minimizing the risk of infection.
A significant change was the expansion of reimbursement for virtual delivery of (CR/ICR/PR). Before the pandemic, Medicare only covered in-person CR programs. However, due to the PHE, CMS temporarily expanded coverage to include virtual delivery of hospital-based CR/ICR/PR, which allowed patients to receive services beyond the walls of the hospital (ie, patient’s home). Additionally, the direct supervision for these services was permitted to include the virtual presence of the physician via two-way, audio-video technology.
These extensions have been great for patients and programs who have utilized virtual CR services to deliver recommended care to patients. Virtual direct supervision has been particularly beneficial for critical access and rural hospitals, where a physician may not be readily on-site and physically available.
However, CMS has most recently announced that the temporary expansion of coverage for virtual delivery of these services will expire on May 11th, 2023, and virtual direct supervision will be allowed until the end of 2023. While this means that Medicare reimbursement ends, bill HR 1406 was introduced to legislation on March 7th, 2023 that could make virtual delivery of CR/ICR/PR and virtual direct supervision permanent.
With the expiration of the PHE approaching, we understand that there tends to be some confusion around terminology and the state of reimbursement. Below is a list of FAQs and their answers:
FAQs
1. What is “virtual” delivery of CR?
Virtual CR refers to synchronous CR delivered with real-time audiovisual communication technology to facilitate patient and clinician interaction during an exercise session.
2. What is “remote” delivery of CR?
Remote CR refers to CR delivered with asynchronous activities without real-time communication between patients and clinicians at the time of an exercise session.
3. What is “hybrid” delivery of CR?
Hybrid CR refers to a mixture of synchronous center-based sessions, virtual sessions and remote sessions delivered to meet the individual needs of the patient. To learn how one program was able to demonstrate success using hybrid CR without utilizing virtual sessions and reimbursement for these services, click here.
4. Can we bill for virtual and remote sessions?
Virtual sessions can be delivered and reimbursed during the PHE using the Hospital Without Walls waivers. This has been possible through the Hospitals Without Walls waivers that were put into effect in March of 2020 in response to the PHE. These waivers will expire at the conclusion of the PHE. This means virtual delivery will no longer be an option for hospital outpatient CR programs after the PHE ends.
For virtual delivery of CR the same conditions of coverage (for center-based CR) must be met, including:
· Clinical indications, required education and exercise program components, exercise requirements, session duration requirements, and physician supervision of the services
· MD/DO referral order is obtained prior to enrollment
· Initial assessment, psychological assessment, outcomes assessment
· Individualized treatment plan (ITP) every 30 days, reviewed and signed by a physician
Remote CR sessions are not billable.
5. What code do we bill for virtual CR?
93797 (if no continuous ECG monitoring) 93798 (with continuous ECG monitoring). A PO modifier will need to be added to the CPT code.
6. Is the reimbursement less for virtual CR?
No, the reimbursement is the same as if the patient participated in a center-based program.
7. Does the patient need to be at their home to receive a virtual CR session?
No, the patient may have their session outside their home, ie community center.
8. Can the clinical staff deliver the virtual session to the patient outside of their CR department or hospital?
CMS remains silent on where the provider needs to be. The supervising physician must be immediately accessible and available while the clinical staff is hosting the session. This virtual direct supervision option of physician supervision will continue to be allowed until the end of 2023 as previously clarified in the final 2023 Medicare regulation.
For more FAQs, click here.
