Executive Summary
- Medicare was previously reimbursing "virtual sessions" of CR/ICR/PR, delivered via synchronous, real-time audio-video. They were reimbursing at the same rate, and using the same CPT codes as onsite sessions.
- This reimbursement was tied to the Public Health Emergency (PHE), which expired on May 11th, 2023.
- However, legislation has 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.
- Now more than ever, we urge you to take action and advocate for increased patient access to CR/ICR/PR services. Click here to submit a form in under a minute that will be directed to your state's representatives and senators expressing your support for HR 1406.
- Because this bill did not pass before May 11th, there will now be a 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 5/12/23: 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 cardiac rehabilitation, intensive cardiac rehabilitation, and pulmonary rehabilitation (CR/ICR/PR). Before the pandemic, Medicare only covered in-person CR/ICR/PR 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 were great for patients and programs who utilized virtual CR/ICR/PR 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.
This temporary expansion of coverage by CMS for virtual delivery of these services has since expired on May 11th, 2023, however 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. Click here to advocate for bill HR 1406 and take action to ensure your voice is heard by contacting your representatives and senators.
With the expiration of the PHE, 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. Virtual delivery is no longer an option for hospital outpatient CR/ICR/PR programs.
For virtual delivery of CR the same conditions of coverage (for center-based CR) needed to 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
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.
Remote CR sessions are not billable.
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 delivery is no longer an option for hospital outpatient CR/ICR/PR programs. Virtual sessions were able to be delivered and reimbursed during the PHE using the Hospital Without Walls waivers that were put into effect in March of 2020 in response to the PHE. These waivers have expired with the conclusion of the PHE.
5. What code was used to bill for virtual CR?
93797 (if no continuous ECG monitoring) 93798 (with continuous ECG monitoring). A PO modifier needed to be added to the CPT code.
6. Was the reimbursement less for virtual CR?
No, the reimbursement was the same as if the patient participated in a center-based program.
7. Did the patient need to be at their home to receive a virtual CR session?
No, the patient could have their session outside their home, ie community center.
8. Could the clinical staff deliver the virtual session to the patient outside of their CR department or hospital?
CMS remained silent on where the provider needed to be. The supervising physician needed to be immediately accessible and available while the clinical staff was 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.
Contact us to learn more!
Email us at info@chanlhealth.com for more information, if you have more questions, or would like a quote.
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Why Chanl Health
At Chanl, we partner with health systems, clinics, and rehab programs to deliver a world-class virtual-hybrid cardiopulmonary rehab program. Our proven virtual-hybrid care solution removes patient barriers to access and provides innovative ways to meaningfully engage in their health. Healthcare providers that use our virtual-hybrid solution can deliver increased quality care to more patients at a lower cost.
