The Centers for Medicare & Medicaid Services (CMS) recently announced plans to continue allowing certain telehealth flexibilities beyond the end of 2024. These changes are part of their proposed rules for Medicare payments in 2025. While most temporary telehealth rules from the COVID-19 pandemic are set to expire, CMS wants to keep some in place. One important change is allowing doctors to supervise other healthcare providers remotely using video calls.
Telehealth Waivers Set to Expire:
The Centers for Medicare & Medicaid Services (CMS) has issued a number of telehealth waivers during the Public Health Emergency (PHE). These waivers included flexibilities around the definitions of “originating site” and “audio-only telehealth,” as well as the types of practitioners who may bill for Medicare telehealth services. The 2023 Consolidated Appropriations Act (CAA) extended certain telehealth flexibilities through December 31, 2024.
In the Proposed Rule, CMS discusses the impact of telehealth flexibilities on beneficiary access to care and notes that the originating site and service site flexibilities extended by the CAA are set to expire on December 31, 2024. CMS seeks comments on the potential impact of the expiration of current flexibilities on overall service utilization for CY 2025.
Absent Congressional action, CMS will not extend these flexibilities into 2025. Nevertheless, CMS has proposed certain changes within its regulatory authority to maintain other important flexibilities for telehealth services.
Proposed Telehealth Flexibilities for 2025
Extended Remote Direct Supervision:
CMS proposes extending the ability to provide certain healthcare services, including incident-to services and many diagnostic tests, under remote supervision using audio/video technology. This means that the supervising practitioner can be located remotely, as long as they are readily available to assist or provide guidance via real-time video or audio.
Permanent Remote Supervision:
CMS also suggests making this remote supervision option permanent for specific services:
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- Incident-to Services: Services provided by auxiliary staff under the direct supervision of a physician or other practitioner.
- Office Visits: Visits described by CPT code 99211, which are for established patients and may not require the physical presence of a healthcare professional.
Essentially, CMS aims to provide more flexibility in healthcare delivery by allowing for remote supervision, especially for certain types of services.
Proposed Revisions to Telehealth Regulations:
Extended Telehealth Flexibility for Enrolled Location as “Distant Site” Address:
To address practitioner safety and privacy concerns, CMS proposes extending the temporary flexibility allowing telehealth providers to use their enrolled location as their distant site address. This change would allow practitioners to bill from their currently enrolled location when providing telehealth services from their home, even after the Public Health Emergency (PHE) ends in 2024. The proposed extension is set to expire on December 31, 2025.
Revised Definition of “Interactive Telecommunications System”:
To accommodate the increasing use of audio-only telehealth services, CMS proposes revising the definition of “Interactive Telecommunications System.” Under the proposed changes, “two-way, real-time audio-only communication technology” would be included as a valid method for providing telehealth services to beneficiaries in their homes, provided certain conditions are met.
Specifically, the distant site physician or practitioner must be technically capable of using a traditional multimedia communications system with both audio and video, but the patient must not be capable of or consent to using video technology. Claims that meet these criteria and are furnished via audio-only telehealth should be submitted with CPT modifier “93.”
Limitations on Home as Originating Site:
It’s important to note that while the proposed changes to the definition of “Interactive Telecommunications System” may expand the use of audio-only telehealth, the restrictions on the patient’s home as an originating site after the PHE ends will likely limit its overall impact. After December 31, 2024, a patient’s home can only serve as an originating site for mental health, substance use disorder, or End-Stage Renal Disease clinical assessments.
New Telehealth Service Additions:
CMS has proposed the provisional addition of specific codes to the Proposed List of Telehealth Services. This list outlines the services that are reimbursable under the Medicare Physician Fee Schedule when provided through telehealth. Although no codes are being added permanently, the proposed provisional additions include:
- HCPS Code G0248 (Home INR Monitoring)
- HCPS Code G0011 (PrEP for HIV)
- HCPS Code G0013 (PrEP for HIV)
- HCPS Codes GCTD1-3 (Caregiver Training in Direct Care Strategies)
- HCPS Codes GCTB1-2 (Caregiver Training for Individual Behavior Management/Modification)
- CPT Codes 97550-97552 (Caregiver Training for Enhancing Patient Functional Performance at Home or in the Community)
- CPT Codes 96202-96203 (Group Behavior Management/Modification Caregiver Training)
CMS Rejects New Telemedicine E/M Codes:
The American Medical Association (AMA) recently introduced 17 new CPT codes (9X075-9X091) to specifically address telemedicine Evaluation and Management (E/M) services. However, the Centers for Medicare & Medicaid Services (CMS) has proposed to reject these new codes, stating that they are redundant with existing office/outpatient E/M codes. CMS plans to assign a procedure status indicator of “I” to these codes, indicating that a more specific code should be used for Medicare billing.
Telehealth Flexibilities Face Uncertainty:
While the Proposed Rule provides some continued flexibilities for telehealth providers, many of these provisions are scheduled to expire at the end of 2024. Although there are ongoing efforts to extend or permanently adopt these policies, the current patchwork of expired and extended waivers creates a complex compliance landscape for providers. This uncertainty may limit access to care for patients.
Medical Billing Companies: The Backbone of Telehealth
Medical billing companies play a crucial role in the success of telehealth services. Here’s why:
1. Complex Coding and Reimbursement:
- Telehealth-specific codes: Telehealth services often require unique codes for billing. Medical billing companies are experts in understanding these codes and ensuring accurate billing.
- Reimbursement regulations: Navigating the complex maze of reimbursement regulations, especially for telehealth services, can be time-consuming. Medical billing companies handle this, ensuring that providers get paid appropriately.
2. Streamlined Operations:
- Time-saving: Medical billing companies can automate many processes, saving providers time and resources.
- Reduced errors: Their expertise in billing practices can help minimize errors and denials.
3. Compliance:
- Regulatory changes: The healthcare landscape, especially regarding telehealth, is constantly evolving. Billing companies stay updated on regulatory changes and ensure providers are compliant.
- Audits: They can assist with audits and investigations, minimizing financial risks.
In conclusion, medical billing companies are essential for the smooth operation and financial success of telehealth services. Their expertise in coding, reimbursement, compliance, and operations ensures that providers can focus on delivering quality care while maximizing revenue.