CMS Telehealth Services After PHE

The 2022 Medicare Physician Fee Schedule Final Rule released on November 2, 2021, by the Centers for Medicare & Medicaid Services (CMS) added certain services to the Medicare telehealth services list through December 31, 2023. Last year, CMS included temporary ‘Category 3’ services to the Medicare services list for the duration of the COVID-19 public health emergency (PHE). Now, these services that would have otherwise been removed after the PHE ends will remain on the telehealth services list through the calendar year 2023. 

‘Category 3’ telehealth services in the final rule include home visits for established patients, emergency department visits, critical care services, and hospital and nursing facility discharge day management services. CMS also extended the inclusion of two new cardiac rehab codes through the calendar year 2023. Beyond the expanded service list, CMS is amending the definition of ‘interactive telecommunications system’ to include audio-only communications technology when used for telehealth services for the diagnosis, evaluation, or treatment of mental health disorders furnished to established patients in their homes under certain circumstances. Generally, however, other services on the Medicare telehealth services list, unless specifically excepted, must still be furnished using audio and video equipment permitting two-way, real-time interactive communication.

Originating Site for Telehealth Services

Section 123 of the CAA removed the geographic restrictions and added the home of the beneficiary as a permissible originating site for telehealth services furnished for the purposes of diagnosis, evaluation, or treatment of a mental health disorder. Section 123 requires for these services that there must be an in-person, non-telehealth service with the physician or practitioner within six months prior to the initial telehealth service and requires the Secretary to establish a frequency for subsequent in-person visits. CMS is implementing these statutory amendments, and finalizing that an in-person, non-telehealth visit must be furnished at least every 12 months for these services, that exceptions to the in-person visit requirement may be made based on beneficiary circumstances (with the reason documented in the patient’s medical record), and that more frequent visits are also allowed under CMS policy, as driven by clinical needs on a case-by-case basis.  

Defining Interactive Telecommunications

CMS is amending the current definition of an interactive telecommunications system for telehealth services, which is defined as multimedia communications equipment that includes, at a minimum, audio and video equipment permitting two-way, real-time interactive communication between the patient and distant site physician or practitioner, to include audio-only communications technology when used for telehealth services for the diagnosis, evaluation, or treatment of mental health disorders furnished to established patients in their homes under certain circumstances.

Limiting Use of Audio-only Telecommunications System

CMS is limiting the use of an audio-only interactive telecommunications system to mental health services furnished by practitioners who have the capability to furnish two-way, audio/video communications, but where the beneficiary is not capable of or does not consent to, the use of two-way, audio/video technology. CMS also finalized a requirement for the use of a new modifier for services furnished using audio-only communications, which would serve to verify that the practitioner had the capability to provide two-way, audio/video technology, but instead, used audio-only technology due to beneficiary choice or limitations. CMS also clarifies that mental health services can include services for the treatment of substance use disorders (SUDs).

We hope that the above-mentioned telehealth billing updates would be helpful for you to receive accurate insurance reimbursement. Billing for telehealth services is challenging due to continuously changing billing guidelines and payer reimbursement policies. Even though CMS has relaxed reimbursement policies for telehealth services, it doesn’t ensure insurance reimbursement for every submitted claim. You will require an expert outsourcing medical billing company like MedicalBillersandCoders (MBC) who stays on top of these billing and documentation guidelines to receive accurate reimbursement. To know more on how we can assist you in billing and coding for telehealth services, contact us at info@medicalbillersandcoders.com/ 888-357-3226

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