$841 Million Rides on Where the Attending Was Standing

CMS reissued its teaching physician booklet last month and put two bullets on the cover under "What's Changed?".

The second one deletes HCPCS code G2012 and adds CPT 98016 in its place. The fee schedule terminated G2012 effective December 31, 2024.

The booklet caught up in August.

The first bullet is the one that matters, and it is the one that will get read wrong.

"Starting January 1, 2026, we permanently allow teaching physicians to participate virtually in all teaching settings..."

That is page 9, and the sentence keeps going.

The Half of the Sentence Everyone Will Skip

Verbatim, the whole thing: "Starting January 1, 2026, we permanently allow teaching physicians to participate virtually in all teaching settings, but only when the service itself is provided virtually as a 3-way telehealth visit with you, the resident, and the patient in different locations."

"All teaching settings" is about geography. Virtual presence used to be legal only at residency training sites outside an OMB-defined metropolitan statistical area, a carve-out CMS built into the CY2021 final rule.

The permanent policy erases the MSA line.

It does nothing to the modality line.

Resident and patient in the same exam room, attending on video from down the hall or across town: still not payable, anywhere, MSA or not. The attending has to be physically present for the key or critical portion, same as 42 CFR 415.172(a) has always said.

So the scenario that would actually relieve a short-staffed program is the one scenario the sentence excludes.