Fee-For-Service and Telehealth Coverage
The Center for Connected Health Policy (CCHP) has published its July 2023 report, “Billing for Telehealth Encounters: An Introductory Guide on Fee-for-Service.” The guide focuses on Medicare Fee for Service (FFS) telehealth policy and reimbursement. 2023BillingGuideFINAL.pdf (cchpca.org)
The report sums up the status of Medicare coverage. Here are some highlights:
- When providing telehealth services to Medicare beneficiaries in their homes through the end of 2023, providers should indicate the in-person Place of Service code 11 and use modifier 95 for video (or 93 for audio-only session) in addition to the CPT code. At least until 2024, DO NOT use telehealth Place of Service codes 02 or 10 for Medicare beneficiaries: While these claims will be paid, they will be paid at a lower reimbursement rate than is due
- Payment parity will be maintained through 2023, but 2024 is not certain
- Beneficiaries can continue to receive telehealth for therapy when at home.
- The in-person visit requirement before a client may be eligible for telehealth is waived through December 31, 2024.
- When seeing a Medicare client in another state, Medicare defers to state law where the client is located regarding whether you must be licensed in that state to see someone in that state legally.
- Medicare cannot reimburse clinicians outside of the country when providing services.
- During the pandemic, providers were allowed to use their work addresses when enrolled in Medicare, even if they provided telehealth from home. However, this will ONLY be allowed until December 31, 2023. The report states, “This has been a long-standing concern for providers … because their home addresses may be publicly accessible.” The information continues: “Since this waiver concerning home addresses may end on December 31, 2023, be sure to work with your Credentialing Staff or … providers on how to suppress their addresses so that they do not appear on the CMS 1500.”
The proposed CY 2024 Physician Fee Schedule (PFS) was released on July 13, 2023. The PFS contains policy changes the Centers for Medicare and Medicaid Services (CMS) proposed for the Medicare program to occur the following year (unless otherwise stated). At this time, these are only proposals. The public has until 5 pm September 11, 2023, to provide comments to CMS regarding these proposed policies.
CMS proposed making necessary regulatory changes to reflect the temporary telehealth policies enacted by the Consolidated Appropriations Act of 2023 (CAA 2023). These provisions included:
- Temporarily removing the geographic and site requirements for the patient location at the time the telehealth interaction takes place
- Temporarily allowing a more expansive list of eligible providers in Medicare to provide services via telehealth, such as physical and occupational therapists and federally qualified health centers (FQHCs), and rural health clinics (RHCs)
- Temporarily allowing some services to continue to be provided via audio-only
- Temporarily suspending the in-person service requirement before the delivery of mental and behavioral services via telehealth or audio-only in cases where the geographic requirement does not apply, the service takes place in the home, and the patient was not being treated for a substance use disorder
These temporary provisions are in effect until December 31, 2024. Beginning January 1, 2024, LMFTs and LPCs are eligible to bill Medicare starting in January 2024. More providers for beneficiaries!!