Our office will be closed until January 1, 2025. We look forward to seeing you in the New Year!

Telehealth Changes Coming for 2025                                              

VMS has received a number of questions about telehealth coverage for 2025. 

Some things are not changing:

  • Vermont’s coverage and payment parity laws (8 V.S.A. § 4100k; 8 V.S.A. § 4100l) that require state-regulated commercial plans to cover and provide reimbursement at parity for telehealth and audio-only services are still in place – BCBSVT and MVP are still paying for telehealth and audio-only services.
  • Medicaid coverage for audio-only and audio-visual telehealth services is ongoing and will not be changing for 2025.
  • Medicare coverage is continuing at least through March 31, 2025 .  Absent action from Congress, Medicare’s telehealth coverage flexibilities were scheduled to end on January 1, 2025, ending most coverage for audio-only services and the ability to provide telehealth when a patient is located in their home vs a medical facility.  This past weekend, Congress passed continuing funding through March 31, 2025, which included extending Medicare telehealth flexibilities for 90 days.  See further description here.

What is changing:

  • The AMA has created new codes for telehealth services – this means that many plans (commercial and Medicaid) are changing coding – while coverage is not ending.
    • In particular, the 2025 Medicare physician fee schedule approved using new telehealth-specific E/M codes (CPT codes 98000-98016) to replace telephone only codes 99441-99443 and in-person E/M codes used with modifiers.  See additional details here regarding how Vermont Medicaid, BlueCross BlueShield Vermont and MVP are adopting these changes.
  • Adding to the confusion, even though these new codes are described in the Medicare fee schedule, Medicare itself has not adopted these new codes and will continue to utilize existing office/outpatient E/M codes (99202-99215) with appropriate POS code to identify the location of the beneficiary and, when applicable, the appropriate modifier to identify the service as being furnished via audio-only communication technology. Medicare will pay separately for new CPT code 98016 in lieu of HCPCS G2012 (Brief communication technology-based service/virtual check-in). They have promised additional educational materials on Medicare coding in 2025. 

Please note: these updates are current as of 12/23/24 but are subject to change before 1/1/2025 – please check with individual payers for more detail. Contact jbarnard@vtmd.org for more information.

AMA: Congress Fails Patients and Physicians as 2025 Medicare Cuts Proceed

This past Saturday, the House and Senate avoided a government shut down and passed a continuing resolution to keep federal agencies and programs operating until March 14. Most of earlier proposed health care package, including provisions that would have provided relief from the 2.83% Medicare cuts in 2025 for physician practices, reduce prior authorization and regulate pharmacy benefit managers, were ejected from the final legislation.  Following is the AMA's statement in response from Bruce A. Scott, M.D., President, American Medical Association.

“The Continuing Resolution utterly fails to address declining reimbursement rates for Medicare, pushing our health system down a path that will have predictable and deleterious results. For the fifth consecutive year, Congress has adjourned and allowed Medicare cuts. What will be the result? Patients struggling to access health care. Physicians closing or selling their private practices while others opt to leave the profession.

“Congress heads home today leaving in place a 2.83 percent cut for doctors. It did not provide a rational permanent, inflation-based update as the Medicare Payment Advisory Commission recommended. It didn’t even offer doctors a Band-Aid in the form of a cut reduction, as the cost of delivering care rises 3.5 percent next year. 

“With this new cut going into effect next year, Medicare payment rates have fallen by 33 percent over the past two decades, when adjusted for the costs of running a practice, leaving physicians struggling to figure out how they can continue to provide needed care to their elderly and chronically ill patients. 

“Congress also inexplicably missed a golden opportunity to improve patient care by refusing to include prior authorization reform in the final package – a reform with vast bipartisan support in both chambers. Leaving it on the cutting room floor is an unnecessary gift to the insurance industry at the expense of our patients. Physicians have unique training and expertise when prescribing appropriate care, and we don’t need insurance companies delaying and interfering with our patients’ vital treatments.

"Physicians are frustrated and patients are angry. Obviously, the Medicare payment system is broken. With another cut almost certain to take effect, Congress must enact meaningful long-term reforms. The American Medical Association has put forward many substantive solutions and is eager to work with the new Congress and administration. Patients and physicians are counting on cooperation to reform Medicare and avoid a sixth year of last-minute cuts and a further hollowing out of access to care.”

For an overview of other provisions that are in and out of the Continuing Resolution, see coverage from CNN.

 

State Approaching Decision Point on Joining AHEAD Model – Public Comments Due January 3rd

The past few weeks have been a busy time for the Agency of Human Services and Green Mountain Care Board in negotiating details of Vermont’s participation with Medicare in the AHEAD payment reform model.  The State has now released a 2-page summary term sheet as well as a full draft agreement with CMS.    The following slides from the AHS Health Care Reform Workgroup also provide important summary information about what it would mean for the State to participate in the Model.  If Vermont is able to keep to negotiated Medicare cost trends, it could bring in an additional $138.9 million in Medicare dollars to the state in 2026 to reinvest in broader population health goals such as access to primary care and availability of services across the continuum of care.  In addition, Medicare will continue to contribute $10.9 million to Blueprint Community Health Team Payments and the Supports and Services at Home program.  Under new Enhanced Primary Care Payments, primary care practices could receive approximately $17 per Medicare beneficiary per month.  A major component of the model is hospital global budgets. At first the state would use a federal hospital global budget methodology, potentially transitioning to a state-based methodology going forward.  Open questions include how hospital will fare under the global budget methodology and the state resources necessary to implement hospital global budgets. 

The Agreement must be signed by the Governor, AHS and the Green Mountain Care Board.  The Green Mountain Care Board is seeking public comments on joining the model by January 3, 2025 and plans to make a decision regarding signing the agreement by the week of the 13th.   Comments submitted by VMS in May can be found here and the organization is currently working on updated comments. 

VTMD.ORG

Vermont Medical Society

134 Main Street

Montpelier, VT 05602

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