As of September 30, several temporary Medicare telehealth flexibilities that were put in place during the COVID-19 pandemic officially came to an end. One of the most significant changes involves the site requirement for telehealth services. Medicare beneficiaries can now only receive telehealth services other than behavioral or mental health services from specific originating sites – meaning the physical location where the beneficiary receives care, usually a healthcare facility or rural clinic. This change marks a departure from pandemic-era rules that allowed patients to receive these services from their homes, a flexibility that had greatly increased access to care for seniors and individuals in underserved areas.
Additionally, Medicare has discontinued coverage for most audio-only telehealth visits, excluding behavioral health services. During the pandemic, audio-only visits were permitted to ensure that patients without video technology could still connect with their providers. Providers must now use both audio and visual communication for most telehealth encounters in order to qualify for Medicare reimbursement. This shift is expected to affect access for patients who lack reliable internet service or compatible devices.
There is also a change to the list of eligible providers who can now provide Medicare covered telehealth services. Before the expiration of these flexibilities, any practitioner who could independently bill Medicare could furnish telehealth, including physical therapists, occupational therapists, speech-language pathologists, and audiologists. Now, the list is once again limited to only physicians, physician assistants, advanced practice registered nurses, certain behavioral health providers, and registered dietitians or nutrition professionals.
Although Congress and CMS have discussed potential legislative fixes, providers, for now, should review the updated billing and compliance requirements to avoid reimbursement issues. It is also recommended to revise scheduling protocols to verify patients’ locations and their methods of communication before each appointment, ensuring that they meet all Medicare requirements.
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