Telehealth services have become more viable especially after the pandemic. This is why telemedicine has become one of the most integral parts of care practices. Telehealth usage has surged during the COVID-19 pandemic, and the federal government has taken several temporary measures to improve access to telehealth services.
The Centers for Medicare and Medicaid Services’ final regulations regarding telehealth services for the financial year 2022 have drawn mixed reactions from healthcare providers. Some of the rule’s components worsen concerns brought on by the COVID-19 pandemic while others ease them.
The Centers for Medicare and Medicaid Services (CMS) issued the 2022 Physician Fee Schedule (PFS) final rule, which focuses on promoting the use of telehealth and other telecommunications technologies. This rule includes updates to payment rates for 2022; expands the use of telehealth for mental health, and makes changes to policies for the 2022 performance year of the Quality Payment Program; among many other provisions.
Medicare authorized payment for office, hospital, and other visits conducted via telehealth for beneficiaries residing in urban areas. Previously, Medicare would only pay for telehealth services for beneficiaries in rural areas who received the services at authorized healthcare sites. The Consolidated Appropriations Act (CAA) of 2021 permanently removed the geographic restrictions for telehealth mental health services and added an individual’s home as a permissible site. CMS continues to evaluate payment for other telehealth services that were added to Medicare’s list of payable telehealth services during the public health emergency, but those services will remain on the services list at least through Dec. 31, 2023.
Additions to the Medicare Telehealth Services
Before the COVID-19 PHE, Medicare only covered certain services via telehealth, like:
- office medical visits
- professional consultations
- office psychiatry services
- any additional service specified by the HHS Secretary when furnished via an interactive telecommunications system.
These services are all included on a list that is amended and published annually in the PFS (the Medicare Telehealth List). Yearly, CMS considers proposals to add services to the Medicare Telehealth List on a Category 1 basis. This means that the proposed services are similar to the professional consultations, office visits, and office psychiatry services that are already covered on the list.
Additionally, CMS adds services to the Medicare Telehealth List on a Category 2 basis if there is proof of clinical benefit when the services are provided through telehealth. Finally, in the CY 2021 PFS final rule, CMS established a new Category 3 to add services to the Medicare Telehealth List on a temporary basis through the end of the year in which the COVID-19 PHE expires. Category 3 services must have a likely clinical benefit when furnished via telehealth.
CMS has now finalized keeping services added to the Medicare Telehealth List on a Category 3 basis until December 31, 2023, to ease the transition from the expanded list of services added to the Medicare Telehealth List during the COVID-19 PHE. During this time, CMS will evaluate whether the services should be permanently added to the Medicare Telehealth List after the COVID-19 PHE has ended. These Category 3 services and their related Current Procedural Terminology (CPT) codes include the following:
- Domiciliary, Rest Home, or Custodial Care Services, Established Patients (99336, 99337)
- Home Visits, Established Patient (99349, 99350)
- Emergency Department Visits, Levels 1-5 (99281-99385)
- Nursing Facilities Discharge Day Management (99315, 99316)
- Psychological and Neuropsychological Testing (96130-96133, 96136-96139)
- Psychological and Neuropsychological Testing (96130-96133; 96136-96139)
- Therapy Services, Physical, Speech/Hearing, and Occupational Therapy, All levels (97161-97168; 97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761, 92521-92524, 92507)
- Hospital Discharge Day Management (99238-99239)
- Inpatient Neonatal and Pediatric Critical Care, Subsequent (99469, 99472, 99476)
- Continuing Neonatal Intensive Care Services (99478-99480)
- Critical Care Services (99291-99292)
- End-Stage Renal Disease Monthly Capitation Payment codes (90952, 90953, 90956, 90959, 90962)
- Subsequent Observation and Observation Discharge Day Management (99217, 99224-99226)
Highlights of Telehealth services Billing changes in 2022
More highlights of Telehealth services Billing changes are summarized below:
- At the end of the public health emergency, Medicare will again restrict most telehealth services to beneficiaries residing in rural areas who receive services at authorized healthcare sites. Under the CAA, however, mental health services will not be subject to these restrictions. To implement this provision of the CAA, an in-person, non-telehealth service must be provided to the beneficiary no more than six months prior to the initial telehealth service. The rule also establishes that an in-person visit must occur every 12 months unless the patient and practitioner agree that the benefits of an annual in-person visit are outweighed by risks and burdens associated with in-person services.
- The definition of “interactive telecommunications system” for purposes of telehealth services has been expanded to include audio-only communications for mental health services for established patients. However, practitioners who utilize audio-only communication must also have the capability to furnish audio-visual communication.
- APA supported CMS’s proposal allowing all psychological and neuropsychological testing services to be provided via telehealth after the PHE ends. CMS adopted this proposal, keeping psychological and neuropsychological testing on the temporary (category 3) telehealth list through the end of 2023.
- Psychologists providing telehealth services to Medicare beneficiaries will see a change in the point of service (POS) codes used to file claims starting in 2022, the Centers for Medicare and Medicaid Services announced October 13 (PDF, 189KB). POS codes are required on health care claims to inform third-party payers, such as Medicare, where the service was rendered.Effective January 1, 2022, POS code 02 will be revised, and a new POS code 10 will be created. When providing telehealth services to patients in their own homes, psychologists will start using POS code 10 and stop using POS code 02.POS code 10 does not apply to patients who are in a hospital or other facility where the patient receives care in a private residence, such as a nursing home or assisted living facility. In those situations, psychologists will continue to use POS 02.
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