The Centers for Medicare and Medicaid Services (CMS) recently released the calendar year (CY) 2022 medicare physician fee schedule final rule. You can read all the details here.
While it was great to get further clarification from CMS regarding the status of the PHE waivers, CMS is looking to collect more data through 2023 to further expand payments for telehealth services “As CMS continues to evaluate the inclusion of telehealth services that were temporarily added to the Medicare telehealth services list during the COVID-19 PHE, we finalized that certain services added to the Medicare telehealth services list will remain on the list through December 31, 2023”.
Here are the key updates related to telehealth:
- CMS extended the inclusion of certain cardiac and intensive cardiac rehabilitation codes through the end of CY 2023.
- Adopting coding and payment for a longer virtual check-in service on a permanent basis.
- 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.
“We are 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 our policy, as driven by clinical needs on a case-by-case basis.”
- 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.
“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. We are also clarifying that mental health services can include services for the treatment of substance use disorders (SUDs)
- CMS finalized its proposal to revise the current regulatory language for rural health clinics (RHC) or federally qualified health centers (FQHC) mental health visits to include visits furnished using interactive, real-time telecommunications technology.
- This change will allow RHCs and FQHCs to report and receive payment for mental health visits furnished via real-time telecommunication technology in the same way they currently do when visits take place in-person, including audio-only visits when the beneficiary is not capable of, or does not consent to, the use of video technology.
- CMS also finalized that an in-person, non-telehealth visit must be furnished at least every 12 months for these services; however, 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 more frequent visits are also allowed under our policy, as driven by clinical needs on a case-by-case basis