APMA submitted comments on February 1 in response to CMS’ Interim Final Rule with Comment Period for Coding and Payment of Virtual Check-in Services and Interim Final Rule with Comment Period for Coding and Payment for Personal Protective Equipment (PPE) (CPT code 99072).
APMA urged CMS to immediately implement and reimburse CPT 99072, which is defined as: Additional supplies, materials, and clinical staff time over and above those usually included in an office visit or other non-facility service(s), when performed during a Public Health Emergency, as defined by law, due to respiratory-transmitted infectious diseases.
As APMA shared with CMS, podiatric physicians and surgeons have experienced an increase in expenses due to the COVID-19 pandemic and are implementing infection controls to ensure their patients and staff are safe, and are experiencing an increase in staff time to engage patients with additional pre-visit screenings and instructions. These additional expenses, however, are not included in the valuation of office and outpatient E/M services or other CPT Codes, and are therefore being borne by physicians' offices. APMA recommended that CMS use funding from the CARES Act or other appropriate funding sources, so physicians are fully reimbursed for these services.
APMA also urged CMS to establish coverage and payment for audio-only E/M services (CPT codes 99441–99443) on a permanent basis. APMA once again commented to CMS that there is a demand among Medicare beneficiaries for audio-only visits, absent the public health emergency, particularly given that many Medicare beneficiaries are not able to access or operate technology that is capable of two-way, audio-visual communication.