Erickson says the ACP has concerns: The code won't generate enough to reimburse the practice for all the expenses incurred to provide the required non-face-to-face services, there will be additional documentation, and there could be the need for additional nurse practitioners or physician assistants to do much of this work on behalf of the practice.
- The physician or another qualified eligible professional, such as an RN or a PA, can provide the service, but someone with clinical expertise has to be available 24/7, "regardless of the time of day or day of the week," according to the rule.
- Because the service now becomes a billing claim, part of the cost will be paid with the patient's coinsurance under Medicare Part B at about 20%. Because of that, patients will have to give the physician consent to receive services billed under G-codes, and of course CMS will require documentation. This might be a problem if patients say no.
- CMS put off two provisions contained in its proposed rule this summer. It dropped the requirement that individuals responding to 24/7 calls have access to the full patient record through an electronic health record. It also dropped the requirement that the practice be certified as a medical home. CMS indicated it will revisit those issues in future rules.
A physician in Kingsport, TN, Blackwelder says that primary care doctors like him don't get paid for reviewing all the pieces of paper that are put before them that require action for their patients.
"One thing to remember is that 37% of Medicare beneficiaries have four or more conditions, so these are extremely complicated patients," he says. "These are things we've already been doing, but I think we still have to figure out how to manage increasingly complex patients."