Posted: January 21, 2022
Since the beginning of the COVID-19 pandemic in early 2020, telehealth services have become a regular and important part of medical care, particularly for at-risk elderly patients. In July 2021, the Centers for Medicare and Medicaid Services (CMS) published its calendar year (CY) 2022 Medicare Physician Fee Schedule (PFS), which dictates what services physicians can provide and be reimbursed for through Medicare. On November 1, 2021, the CMS passed its final rule on the CY 2022 PFS, putting into place some extensions for codes created in response to the pandemic.
Telemedicine and digital health technologies are likely to stick around in a post-COVID world. CMS data reports that prior to the pandemic, only 15,000 telehealth visits per week were received by Medicare patients. The number of visits grew to just under 1.7 million visits per week by April 2020.
While the data supports that telehealth is being successfully integrated into healthcare, there will be no new telehealth services approved for CY2022. Currently, Medicare covers about 270 services on a permanent basis with another 160 services approved temporarily through the end of the public health emergency. There were additional services proposed; however, none of the requests met the criteria to be permanently added to the Medicare telehealth services list.
CMS created a list of 13 codes in 2020 known as Category 3 codes. These codes designate telehealth services that were to be covered temporarily during the public health emergency. CMS has not yet deemed these services as meeting requirements for permanent coverage, but providers are asked to collect clinical data that could help support the permanent designation in the future. In the meantime, CMS has extended the Category 3 codes until December 31, 2023.
In 2021, CMS created Communication Technology-Based Services (CTBS) to allow coverage of brief services conducted over various technologies like phone or video call. The code is intended to be used when the patient’s problem is non-emergent but requires more than a short assessment. It is not intended to replace in-person services but can help avoid unnecessary office visits for at-risk patients.
For CY2022, CMS has permanently adopted the CTBS code. The stipulations are that the visit must not be related to an emergency medicine service within the previous seven days, and it cannot lead to an emergency medicine service within the subsequent 24 hours.
In the Consolidated Appropriations Act, 2021 (CAA), Section 123 removed a geographic restriction and allowed the home of the service beneficiary as a permissible originating site for telehealth pertaining to the diagnosis, evaluation and treatment of a mental health disorder. In order for this rule to apply, the patient must have received an in-person, non-telehealth visit with the provider within six months of the initial telehealth service and should continue to have at least once in-person visit every 12 months during the course of treatment.
Interactive telecommunications systems for telehealth service is currently 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 the distant site physician or practitioner. CMS is updating the definition to include audio-only communications technology, specifically for telehealth services for diagnosing, evaluating and treating mental health disorders for established patients.
If you have questions about leveraging telehealth solutions for your practice,contact Let’s Talk Interactive today.