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HomeHealth LawCMS Updates Checklist of Telehealth Providers for CY 2023

CMS Updates Checklist of Telehealth Providers for CY 2023

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On February 13, 2023, the Facilities for Medicare and Medicaid Providers (CMS) printed the revised Checklist of Telehealth Providers for Calendar 12 months (CY) 2023 (Checklist). The Checklist consists of the companies which are payable underneath the Medicare Doctor Charge Schedule when furnished through telehealth.

In its replace, CMS clarified that every one codes on the Checklist can be found by means of the top of CY 2023. Pursuant to the 2023 Consolidated Appropriations Act (“CAA”), sure telehealth flexibilities (together with with respect to supplier and affected person location) can be prolonged by means of December 31, 2024.[1] Subsequently, codes on the Checklist can be billable when furnished through telehealth, regardless as an illustration of the geographic location of the supplier and the affected person by means of the top of this 12 months.[2] CMS anticipates additional revisions to the Checklist by means of the CY 2024 Doctor Charge Schedule remaining and proposed guidelines; suppliers ought to fastidiously assessment these guidelines when printed to find out the scope of telehealth protection that can be accessible after 2023.

As mentioned in additional element beneath, the supply and billing of companies on the Checklist are instantly impacted by the standing of telehealth waivers and flexibilities promulgated through the PHE, and which suppliers ought to take into account in figuring out present protection standing for his or her companies. 

Originating Web site – Persevering with Flexibility by means of 2024

Through the PHE, the definition of “originating web site” is expanded to imply any web site in the US, together with a person’s house. Previous to the PHE, “originating web site” solely included the affected person’s house in sure restricted circumstances. Originating web site geographic restrictions are completely waived for behavioral/psychological telehealth companies, and the CAA extends this flexibility by means of December 31, 2024 for non-behavioral/psychological telehealth companies.

Audio-Solely Telehealth Providers and Phone E/M Codes – Persevering with Flexibility by means of 2023 and Past

The usage of audio-only platforms for sure E/M companies and behavioral well being counseling and academic companies is permitted through the PHE. Previous to the PHE, CMS typically required these companies to be furnished with audio-video expertise. The CAA extends this flexibility by means of December 31, 2024.

Additionally through the PHE, phone analysis and administration (E/M) companies (CPT codes 99441-99443) are on the Checklist on a brief foundation and Medicare cost is equal to the cost for workplace/outpatient visits with established sufferers. Moreover, practitioners are allowed to invoice E/M companies furnished utilizing audio-only expertise, which in any other case would have been reported as an in-person or telehealth go to, utilizing these codes. As a result of these codes are included on the revised Checklist, we perceive that they are going to stay billable (and payable at equal charges) by means of December 31, 2023.

Practitioner Sorts – Persevering with Flexibility by means of 2024

The sorts of practitioners who might invoice for Medicare telehealth companies from a distant web site are expanded through the PHE to incorporate certified occupational therapists, certified bodily therapists, certified speech-language pathologists, and certified audiologists. Previous to the PHE, “practitioner” solely included doctor assistants, nurse practitioners, scientific nurse specialists, licensed registered nurse anesthetists, licensed nurse-midwifes, scientific social employees, scientific psychologists, and registered dietitians or vitamin professionals. The CAA extends this flexibility by means of December 31, 2024.

RPM Codes – Reestablished Limitations with Some Continued Flexibility

Through the PHE, clinicians are permitted to invoice for RPM companies furnished to each new and established sufferers. Previous to the PHE, an initiating go to was required to invoice for RPM companies. Upon the top of the PHE, a longtime relationship with the affected person previous to offering RPM companies will as soon as once more be required.

Previous to the PHE, clinicians might solely invoice for CPT codes 99453 and 99454 with at the least 16 days of collected knowledge. Through the PHE, clinicians are permitted to report CPT codes 99453 and 99454 with as little as two days of collected knowledge if a affected person is recognized with, or suspected of getting COVID-19. After the PHE ends, 16 days of collected knowledge will as soon as once more be required to report these codes.

Clinicians are permitted to furnish RPM companies to sufferers with acute or continual circumstances through the PHE. Previous to the PHE, RPM companies have been restricted to sufferers with continual circumstances. CMS has clarified RPM companies might proceed to be furnished to sufferers with continual or acute circumstances after the PHE ends.

Frequency Limitations on Sure Telehealth Codes – Reestablished Limitations

Frequency limitations on the furnishing of companies reportable by CPT codes 99231-99233, 99307-99310, and G0508-G0509 are eliminated through the PHE. After the top of the PHE, frequency limitations will revert to pre-PHE requirements, and subsequent inpatient visits might solely be furnished through Medicare telehealth as soon as each three days (CPT codes 99231-99233), expert nursing facility visits might solely be furnished through Medicare telehealth as soon as each fourteen days (CPT codes 99307-99310), and important care consults might solely be furnished through Medicare telehealth as soon as per day (CPT codes G0508-G0509).

Clinician Licensure – Reestablished Limitations

Through the PHE, CMS waived the Medicare requirement {that a} doctor or non-physician practitioner be licensed within the state wherein they’re practising if the doctor or practitioner 1) is enrolled as such within the Medicare program, 2) has a sound license to observe within the state mirrored of their Medicare enrollment, 3) is furnishing companies — whether or not in individual or through telehealth — in a state wherein the emergency is happening in an effort to contribute to reduction efforts in his or her skilled capability, and 4) will not be affirmatively excluded from observe within the state or every other state that’s a part of the part 1135 emergency space. Upon the termination of the PHE, licensure restrictions will revert again to a deferral to state legislation.

Different Concerns

Because the termination of the PHE commences, suppliers ought to intently assessment the evolving scope of telehealth protection to make sure compliance with relevant CMS guidelines. Our workforce will proceed to watch telehealth developments and supply updates as they come up. Suppliers with questions or in search of counsel can contact any member of our Healthcare workforce for help.

FOOTNOTES

[1] For added info relating to the CAA please see the next useful resource: Key Healthcare Provisions of the Consolidated Appropriations Act, 2023 | Healthcare Legislation Weblog (sheppardhealthlaw.com).

[2] The CY 2023 Doctor Charge Schedule Remaining Rule clarified that companies that have been added to the Checklist on a Class 3 foundation would stay on the Checklist by means of December 31, 2023. Codes that weren’t on the listing on a Class 1, 2 or 3 foundation however have been impacted by the extension of flexibilities within the CAA can be accessible 151 days after the top of the PHE. CY 2023 Doctor Charge Schedule, 87 Fed. Reg. 69404, 69460-69461 (Nov. 18, 2022).

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