The COVID-19 pandemic has created significant disruption of the delivery of genetic counselor services as healthcare facilities attempt to mitigate patient and genetic counselor exposure to the virus.

On April 15, NSGC held a webinar that explains how genetic counselors can incorporate telehealth into their practice and reimbursement strategies. A recording of the webinar is now available.

A few key takeaways for genetic counselors who provide telehealth are:

• Licensed genetic counselors are independent practitioners and should be able to provide telehealth unless prohibited by state law.
• For those working in unlicensed states, the path forward is not as clear.
• For commercial health plans, CPT® code 96040 is approved for use with the (95) telehealth modifier.
• Genetic counselors are prohibited from providing telehealth services to Medicare beneficiaries as they are not recognized Medicare practitioners and “incident to” rules cannot be met. Services may only be provided if a supervising physician also joins the telehealth service and the physician would then bill for the service.
• As genetic counseling is a covered benefit under Medicare and it is reimbursed as a “reasonable and necessary” service when testing is indicated, the service cannot be provided by a genetic counselor for free as it would be considered an inducement (fraud).

H.R. 3235 would completely change the dynamic of delivering services to Medicare beneficiaries. The bill would recognize genetic counselors as healthcare practitioners and allow them to be reimbursed by the Medicare program. Delivering genetic counselors’ services via telehealth would be allowed. The result would be the harmonization of delivery models across the payer spectrum. 

Congress needs to know that genetic services are being disrupted as a result of COVID-19. Patients are frustrated, as are genetic counselors. We encourage you to email your members of Congress today and explain how the current environment is impacting patient care. A draft email is available. Please feel free to edit and make the email personal. 

There will be several legislative packages that move through Congress this year addressing short-term healthcare policies to further address the response to the pandemic and long-term systematic changes that need to occur to ensure our country is better prepared to deliver high-quality healthcare. The next COVID-19 package is likely to come together in mid to late May and it is our collective job to make sure Congress appreciates that inaction on CMS genetic counselor recognition will result in unnecessary harm to Medicare beneficiaries.

This article was published in the April 2020 Advocate Newsletter.

John Richardson, NSGC Senior Director of Policy and Government Relations