Luckily, we have managed to overcome this global beast. Quarantines, masks, and social distancing are slowly becoming the relics of the past. However, telemedicine is undoubtedly here to stay. Many healthcare providers are wondering about a potential difference between telehealth before and after COVID, asking questions like “when will telehealth coverage end?”.
The CMS took the future of telemedicine in post covid life into an account already in the beginning of this year. In January 2022, a major new reimbursement policy was released, and it came into effect on April 1 of this year. The 2022 Medicare Telehealth Physician Fee Schedule is largely based upon the 2021 Consolidated Appropriations Act that focuses on telemedicine and access to mental health services.
First, effective on and after the official end of the PHE, healthcare providers will still be allowed to render services aimed at diagnosis, evaluation, or treatment of mental health disorders as telemedicine to any patients regardless of their residence within a state.
Second, the CMS and commercial carriers have already started to require healthcare providers to append an applicable Place of Service (POS) codes 02 and 10 for telemedicine services rendered in locations other than a patient’s home and those rendered in a patient’s home, respectively. The policy also outlines that telehealth mental health services may only be rendered via real-time audio and visual interactive telecommunications. If the patient does not have the technical capacity or the availability of real-time audio and visual interactive telecommunications, or they don’t consent to the use of real-time video technology, Medicare will only pay for audio-only communication for telehealth mental health services to established patients located in their homes.
Third, after the end of the PHE, Medicare will pay for mental health telemedicine visits only in cases when a patient had a non-telehealth visit within 6 months since the date of service. This means that all telehealth mental health patients will need to have at least one in-person visit no later than 6 months after the PHE. After the PHE and after the initial 6-month in-person visit, a patient must have a subsequent non-telehealth in-person visit within 12 months of the initial 6-month in-person visit date. In cases when a practitioner who rendered telemedicine service is not able to have an in-person encounter, Medicare will allow physicians from the same specialty and provider group to render the service.
Finally, the CMS has introduced two new modifiers that can be applied on mental health procedures rendered through telecommunication technology:
• FQ - A telehealth service was furnished using real-time audio-only communication technology
• FR - A supervising practitioner was present through a real-time two-way, audio/video communication technology
You can retrieve a full list of procedures that can be performed rendered via telemedicine here.
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