( 2 ) Sum the claim or line item payment amounts, on the claims or line items identified in paragraph (d)(1)(i)(B)( 1 ) of this section
We additionally acknowledge that coding already exists under the PFS that accounts for the resources involved in conducting these types of assessments

Specifically, we would add internet and patient portal as examples of asynchronous non-face-to-face consultation methods and specify that the practitioner would provide other communication technology-based services, including remote evaluation of pre-recorded patient information and interprofessional telephone/internet/EHR referral service(s), to maintain ongoing communication with patients, as appropriate as well as specify access to patient-initiated digital communications that require a clinical decision, such as virtual check-ins and digital online assessment and management and E/M visits (or e-visits). Providing asynchronous non-face-to-face consultation methods and other CTBS services is an essential element of the delivery of care under an advanced primary care model of care, and we believe this will allow patients to access their usual source of care more conveniently (see section II.G.2.c.(3) of this proposed rule)
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