The most common question asked by healthcare leaders is how to get reimbursed for telehealth services. The Centers for Medicare & Medicaid Services published policy updates for Medicare telehealth services. lock Hospitals can bill HCPCS code Q3014, the originating site facility fee, when a hospital provides services via telehealth to a registered outpatient of the hospital. This blog is made available by Foley & Lardner LLP (Foley or the Firm) for informational purposes only. January 14, 2022. on the guidance repository, except to establish historical facts. Under the emergency waiver in effect, the patient can be located in any provider-based department, including the hospital, or the patients home. Heres how you know. 200 Independence Avenue, S.W. That change did not require the professionals real-time presence at, or live observation of, the service via interactive audio-video technology throughout the performance of the procedure. Federal government websites often end in .gov or .mil. A federal government website managed and paid for by the U.S. Centers for Medicare & Medicaid Services. Communicating with Foley through this website by email, blog post, or otherwise, does not create an attorney-client relationship for any legal matter. On February 13, 2023, the Centers for Medicare and Medicaid Services (CMS) published the revised List of Telehealth Services for Calendar Year (CY) 2023 (List). The supervising professional need not be present in the same room during the service, but the immediate availability requirement means in-person, physical - not virtual - availability. Share sensitive information only on official, secure websites. Telehealth for American Indian and Alaska Native communities, Licensure during the COVID-19 public health emergency, Medicare payment policies during COVID-19, Billing and coding Medicare Fee-for-Service claims, Private insurance coverage for telehealth, National Policy Center - Center for Connected Health Policy fact sheet, this reference guide by the Center for Connected Health Policy, Append modifier 95 to indicate the service took place via telehealth, COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing, Medicare Fee-For-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19), Federally Qualified Health Centers and Rural Health Clinics, Billing for Telehealth Encounters: An Introductory Guide on Fee-for-Service, Telehealth CPT codes 99441 (5-10 minutes), 99442 (11-20 minutes), and 99443 (20-30 minutes), Reimbursements match similar in-person services, increasing from about $14-$41 to about $60-$137, retroactive to March 1, 2020. There are no geographic restrictions for originating site for non-behavioral/mental telehealth services. CMS decided that certain services added to the Medicare Telehealth Services List will remain on the List until December 31, 2023. This will give CMS more time to consider which services it will permanently include on the Medicare Telehealth Services List. Generally, any provider who is eligible to bill Medicare for their professional services is eligible to bill for telehealth during this period. In the final PFS rule, CMS finalizes the extension of coverage of those temporary telehealth codes until 151 days after the PHE ends. This document includes regulations and rates for implementation on January 1, 2022, for speech- Occupational therapists, physical therapists, speech language pathologists, and audiologist may bill for Medicare-approved telehealth services. Telehealth is witnessed high and low acceptance during COVID-19 pandemic last year, and it might play a key role in care delivery in 2022. CMS proposed adding 54 codes to that Category 3 list. Thus, interested parties are encouraged to submit such evidence ahead of the February 2023 deadline if they wish to see Category 3 services added on a permanent basis. Some non-behavioral/mental telehealth services can be delivered using audio-only communication platforms. In the CY 2023 Final Rule, CMS finalized alignment of availability of services on the telehealth list with the extension timeframe enacted by the CAA, 2022. In MLN Matters article no. delivered to your inbox. To find the most up-to-date regulations in your state, use thisPolicy Finder Tool. There are no geographic restrictions for originating site for behavioral/mental telehealth services. Telehealth has emerged as a cost effective and extremely popular addition to in-person care for a wide range of patient needs. The U.S. Department of Health and Human Services took a range of administrative steps to expedite the adoption and awareness of telehealth during the COVID-19 pandemic. In 2020, CMS broadened which telehealth services may be reimbursed for Medicare patients. Telehealth services: Billing changes coming in 2022 Medicare will require psychologists to use a new point of service code when filing claims for providing telehealth services to patients in their own homes. You will need to equip your locums with the needed technology, however, as most agencies will not provide this equipment. Medicare added over one hundred CPT and HCPCS codes for the duration of the COVID-19 public health emergency. Also referred to as access of parity, coverage or service parity requires the same services becoveredfor telehealth as they would be if delivered in person. Should not be reported more than once (1X) within a 7-day interval, Interprofessional telephone/internet/EHR referral service(s) provided by a treating/requesting physician or other QHP, Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment, Brief communication technology-based service, e.g. Section 123 of the Consolidated Appropriations Act (CAA) eliminated geographic limits and added the beneficiarys home as a valid originating place for telehealth services provided for the purposes of diagnosing, evaluating or treating a mental health issue. Telehealth billing guidelines fall under three main categories: Medicare, Medicaid, and private payer. Here is a summary of the updates on the CMS guidelines for telehealth billing: Find out how much revenue your practice may be missing with this free calculator. Telehealth visits billed to Medicare are paid at the same Medicare Fee-for-Service (FFS) rate as an in-person visit during the COVID-19 public health emergency. Section 123 of the Consolidated Appropriations Act (CAA) also 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. Under PHE waivers, CMS allowed separate reimbursement of telephone (audio-only) E/M services (CPT codes 99441-99443), something embraced by many practitioners and patients, particularly patients in rural areas or without suitable broadband access, as well as patients with disparities in access to technology and in digital literacy. endstream endobj 179 0 obj <. physical therapy and occupational therapy, complementary and integrative approaches, and community-based care, as appropriate. She enjoys all things outdoors-y, but most of all she loves rock climbing in the Wasatch mountains. CMS planned to withdraw these services at the end of thethe COVID-19 Public Health Emergency or December 31, 2021. Medicare billing and coding guidelines on telehealth for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs). Whether youre new to the telehealth world or a seasoned virtual care expert, its critical to keep track of the billing and coding changes for this evolving area of medicine. website belongs to an official government organization in the United States. billing guidelines will remain in effect until new rules are adopted by ODM following the public health emergency . CMS has amended 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 allowing two-way, real-time interactive communication between the patient and a 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 problems. Medicare increased payments for certain evaluation and management visits provided by phone for the duration of the COVID-19 public health emergency: In addition, Medicare is temporarily waiving the audio-video requirement for many telehealth services during the COVID-19 public health emergency. CMS has updated the Telehealth medical billing Services List to show minor changes due to various activities, such as the CY 2022 MPFS Final Rule and legislative changes from the Consolidated Appropriations Act of 2021. CMS itself proposed five new codes to be added to the Medicare Telehealth Services list on a permanent basis: The prolonged E/M services and chronic pain management codes were added on a Category 1 basis because they are sufficiently similar to other Medicare Telehealth Services currently listed on a Category 1 basis. K"jb_L?,~KftSy400 T %Xl c7LNL~23101>"Aouo%&\{u/Sts$Txb| y:@ 0 How to Spot Red Flags With Your Medical Billing, How to Spot Red Flags In Your Medical Billing, To help doctors and practice managers stay ahead of the curve, Gentem has put together a cheat sheet of telehealth codes approved by the Centers for Medicare and Medicaid Services (CMS). However, notably, the first instance of G3002 must be furnished in-person without the use of telecommunications technology. There are two types of pay parity: Payment parity is the requirement that telehealth visits bereimbursedat the same payment rate or amount as if care had been delivered in person. A lock () or https:// means youve safely connected to the .gov website. It is not meant to convey the Firms legal position on behalf of any client, nor is it intended to convey specific legal advice. Official websites use .govA 221 0 obj <>stream The 2022 Telehealth Billing Guide Announced The Center for Connected Health Policy (CCHP) has released an updated billing guide for telehealth encounters. Share sensitive information only on official, secure websites. Federal legislation continues to expand and extend telehealth services for rural health, behavioral health, and telehealth access options. Read the latest guidance on billing and coding FFS telehealth claims. In the final rule, CMS clarified the discrepancy noted in our write-up of the proposed PFS that could have led to Category 3 codes expiring before temporary telehealth codes if the PHE ends after August 2023. hbbd```b``V~D2}0 F,&"6D),r,6lC("$:[PDJC30VHe?S' p On Tuesday, CMS announced it finalized rules that allow for greater flexibility in billing and supervising certain types of providers as well as permanently covering some telehealth services provided in Medicare beneficiaries' homes. Other changes to the MPFS for telehealth Make sure your billing staff knows about these changes. The rule was originally scheduled to take effect the day after the PHE expires. Accordingly, do not act upon this information without seeking counsel from a licensed attorney. Can value-based care damage the physicians practices? The Consolidated Appropriations Act of 2023extended many of the telehealth flexibilities authorized during the COVID-19 public health emergencythrough December 31, 2024. endstream endobj startxref Medicare patients can receive telehealth services authorized in the. G3002 (Chronic pain management and treatment, monthly bundle including, diagnosis; assessment and monitoring; administration of a validated pain rating scale or tool; the development, implementation, revision, and/or maintenance of a person-centered care plan that includes strengths, goals, clinical needs, and desired outcomes; overall treatment management; facilitation and coordination of any necessary behavioral health treatment; medication management; pain and health literacy counseling; any necessary chronic pain related crisis care; and ongoing communication and care coordination between relevant practitioners furnishing e.g. Official websites use .govA Therefore, 151 days after the PHE expires, with the exception of certain mental health telehealth services, audio-only telephone E/M services will revert to their pre-PHE bundled status under Medicare (i.e., covered but not separately payable, also known as provider-liable). CMS rejected all stakeholder requests to permanently add codes to the Medicare Telehealth Services List. Required initial face-to-face visit at least 30 minutes provided by a physician or other qualified health professional; first 30 minutes personally provided by physician or other qualified health care professional, per calendar month. In the final rule, CMS rejected requests to make virtual direct supervision a permanent feature in Medicare. ( Each state, however, has ongoing legislation which reevaluates telehealth reimbursement policies, both for private payer and CMS services. %%EOF The modifiers are: For Telehealth services, every payer has unique billing guidelines and reimbursement policies, we can assist you in getting accurate reimbursements for your practice. Sources: Consolidated Appropriations Act, 2021(PDF), Consolidated Appropriations Act, 2022(PDF), CMS CY 2022 Physician Fee Schedule(PDF), CMS CY 2023 Physician Fee Schedule(PDF), Source: Consolidated Appropriations Act, 2023(PDF). By clicking on Request a Call Back button, we assume that you are accepting our Terms and Conditions. With the extension of the PHE through January 11, 2023, virtual direct supervision will be available through at least the end of 2023. 7500 Security Boulevard, Baltimore, MD 21244, An official website of the United States government, HRSAs Medicare Telehealth Payment Eligibility Analyzer. 7500 Security Boulevard, Baltimore, MD 21244, An official website of the United States government, List of Telehealth Services for Calendar Year 2023 (ZIP). However, some CPT and HCPCS codes are only covered until the current Public Health Emergency Declarationends. An official website of the United States government. This will give CMS more time to consider which services it will permanently include on the Medicare Telehealth Services List. Temporary telehealth codes are those services added to the Medicare Telehealth Services List during the PHE on a temporary basis, but which were not placed into Category 1, 2, or 3. Do not use these online E/M codes on the day the physician/QHP uses codes (99201-99205), Prolonged Services w/o Direct Patient Contact, Prolonged E/M service before and/or after direct patient care. CMS also extended inclusion of certain cardiac and intensive cardiac rehabilitation codes through the end of CY 2023. During pandemic, guidelines has been loosened for more acceptance of telehealth services as in-person care may not be available all the time. %%EOF Should be used only once per date, Office/ Outpatient visit for E/M of new patient, Problem focused hx and exam; straightforward medical decision making, Office/ Outpatient visit for E/M of established patient, Same as above (99201-99205), but for established patient, Inter-professional Telephone/ Internet/ EHR Consultation, Interprofessional telephone/internet/EHR assessment and management services provided by a consultative physician, including a verbal and written report to the patients treating/requesting physician or other QHP. endstream endobj 315 0 obj <. Secure .gov websites use HTTPS An official website of the United States government. Some telehealth codes are only covered until the Public Health Emergency Declarationends. Reimbursement rates for telehealth services can vary by payer and whether youre receiving payment from a private payer, Medicare, or a state Medicaid plan. CMS also rejected a request from a commenter to create a third virtual check-in code with a crosswalk to CPT code 99443 for a longer virtual check-in than the existing G2012 (5-10 minutes) and G2252 (11-20 minutes) codes. Secure .gov websites use HTTPSA Gentems cutting-edge RCM platform will give you greater control over your organizations revenue cycle through AI-powered automation and in-depth analytics. Consequently, healthcare providers are experiencing a surge in demand for Telehealth services. In its update, CMS clarified that all codes on the List are . To help your healthcare organization achieve its goals and get the most out of your telehealth program, weve identified five critical components that will help you to expand your program and navigate the latest telehealth rules and regulations. Some of these telehealth flexibilities have been made permanent while others are temporary. NOTE: Pay parity laws are subject to change. This will give CMS more time to consider which services it will permanently include on the Medicare Telehealth Services List. submitted by Ohio Medicaid providers and are applicable for dates of service on or after November . On this page: Reimbursement policies for RHCs and FQHCs Telehealth codes for RHCs and FQHCs In most cases, federal and state laws require providers delivering care to be licensed in the state from which theyre delivering care (the distant site) and the state where the patient is located (the originating site). She enjoys telling the stories of healthcare providers and sharing new, relevant, and the most up-to-date information on the healthcare front. In addition, Federally Qualified Health Centers and Rural Health Clinicscan bill Medicare for telehealth services as a distant site. Learn how to bill for asynchronous telehealth, often called store and forward". Due to the provisions of the You can decide how often to receive updates. Telehealth Billing Guidelines CMS decided that certain services added to the Medicare Telehealth Services List will remain on the List until December 31, 2023. Teaching Physicians, Interns and Residents Guidelines. 205 0 obj <>/Filter/FlateDecode/ID[<197D36494530E74D8EEC5854364E845B>]/Index[178 44]/Info 177 0 R/Length 123/Prev 173037/Root 179 0 R/Size 222/Type/XRef/W[1 3 1]>>stream Telehealth Origination Site Facility Fee Payment Amount Update . Foley expressly disclaims all other guarantees, warranties, conditions and representations of any kind, either express or implied, whether arising under any statute, law, commercial use or otherwise, including implied warranties of merchantability, fitness for a particular purpose, title and non-infringement. For more details, please check out this tool kit from. We have updated and simplified the Medicare Telehealth Services List to clarify that these services will be available through the end of CY 2023, and we anticipate addressing updates to the Medicare Telehealth Services List for CY 2024 and beyond through our established processes as part of the CY 2024 Physician Fee Schedule proposed and final rules.