When these kinds of check-in services are furnished prior to an office visit, then we would currently consider them to be bundled into the payment for the resulting visit, such as through an evaluation and management (E/M) visit code. However, in cases where the check-in service does not lead to an office visit, then there is no office visit with which the check-in service can be bundled. To the extent that these kinds of check-ins become more effective at addressing patient concerns and needs using evolving technology, we believe that the overall payment implications of considering the services to be broadly bundled becomes more problematic…. Therefore, we are proposing to pay separately, beginning January 1, 2019, for a newly defined type of physicians’ service furnished using communication technology. This service would be billable when a physician or other qualified health care professional has a brief non- face-to-face check-in with a patient via communication technology, to assess whether the patient’s condition necessitates an office visit.
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