Telehealth Reimbursement: What to Expect Post-Public Health Emergency (PHE)

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Anticipated Changes to Medicare and Private Payer Telehealth Reimbursement Rules

Telehealth reimbursement is undergoing change at the federal as well as state levels. “The expansion of telehealth and the offering of new services that were not previously covered really enabled physicians to care for their patients in the midst of this crisis,” said Todd Askew, the AMA’s senior vice president of advocacy, during a recent AMA COVID-19 Update. We have moved forward a decade in the use of telemedicine in this country, and it’s going to become and will remain an increasingly important part of physician practices going forward.” While the AMA and many others are advocating for the continued support of telehealth reimbursement post-pandemic, healthcare providers and practice leaders should anticipate and prepare for a return to more standardized regulation after the public health emergency (PHE).

Telehealth Medicare Reimbursement Finds Support in Congress

US Congressional support for permanently expanding reimbursement and other forms of telehealth access seems to be rising, though challenging questions persist around payment, timing and which flexibilities should be retained after the COVID-19 PHE expires (see here).

Anticipated New CMS Rules

The Centers for Medicare and Medicaid Services (CMS) is expected to issue new rules for telehealth in the release 2021 Physician Fee Schedule in the autumn of this year. Today, Medicare reimburses for specific services when delivered via live video (see here). These new rules are expected to specify what Medicare will cover regarding telehealth services, details of telehealth billing going forward, and which documentation will be required for telehealth reimbursement. It is highly probable that private payers will adopt the Medicare rules, but how quickly they will follow suit is unknown, can differ by state as well as by carrier.

All providers may want to review these new Medicare billing rules as well as any state-specific legislative or regulatory telehealth reimbursement requirements (see here). While the Office of Inspector General (OIG) has deferred random audits during the PHE, expect them to resume at the end of the emergency. 

It is also recommended to review individual payer websites for any changes in telehealth policies for 2021. It can be expected that post-PHE, payers will enact policies to limit the scope of coverage (see here‎). Many patients appreciate the convenience of telehealth, and it is likely the number of telehealth visits will continue to increase post-PHE. As patients use telehealth to interact with their physicians more often, payers will be expected to reimburse more visits.

Provider Considerations

When it comes to telehealth reimbursement, an important consideration for providers is whether they use the CMS-approved CPT codes for reimbursement. CMS publishes a list of currently approved telehealth codes. The American Medical Association (AMA) compiles the CPT handbook, in which the “starred appendix” includes those codes that are telehealth eligible. Post-PHE, providers will also want to check that the telehealth service is a covered benefit under a patient’s insurance policy. It is also important for providers to understand their state’s parity regulations. In some states, parity regulations require that the payer reimburse the same amount for a telehealth visit as an in-person visit (see here).

Staying Ahead of Change

How can telehealth providers prepare for the changes expected to come post public health emergency? Now is the time to be thinking about what changes need to be made to manage an increased volume of telehealth visits. These suggestions may be worth considering:

  • Proactively review strategic plans and ensure the ability to meet the pre-PHE telehealth requirements, as well as the most-probable changes. This includes meeting all state-level telehealth, licensing, and credentialing requirements.
  • Check which payers require providers to be registered in-network to be covered and take steps to become a member of those networks that make sense for your organization to be successful at telehealth billing.

Also, advocate for the right changes.

  • Comment on rules during all open comment periods.
  • Use technology to make the reimbursement process more effective. For example, make sure the same front-end registration processes are in place for telehealth patients as in-person patients.
  • Use patient demographics verification and insurance coverage discovery and eligibility software to maximize reimbursement.

Tips for Telehealth Billing Moving Forward Post-PHE

Use this time to prepare for future telehealth billing requirements. Follow these tips to position your service for success post-PHE:

  • Put a process in place to capture patient informed consent upfront (see here‎)
  • Thoroughly review national and state-level policies impacting telehealth practice and reimbursement
  • Ensure licensing and credentialing is in proper order for all providers
  • Make sure a practice or emergency physician group is set up correctly to succeed with telehealth once the PHE has lifted
  • Evaluate how technology solutions can help optimize reimbursement
How Can I Get Paid More for Telehealth?

Increase your telehealth revenue. Industry leaders explain how, when, and why to use telehealth CPT codes and modifiers.

Disclaimer: The Telebehavioral Health Institute (TBHI Telehealth.org) offers information as educational material designed to inform you of issues, products, or services potentially of interest. We cannot and do not accept liability for your decisions regarding any information offered. Please conduct your due diligence before taking action. Also, the views and opinions expressed are not intended to malign any organization, company, or individual. Product names, logos, brands, and other trademarks or images are the property of their respective trademark holders. There is no affiliation, sponsorship, or partnership suggested by using these brands unless contained in an ad. We do not and cannot offer legal, ethical, billing technical, medical, or therapeutic advice. Use of this site constitutes your agreement to TBHI Privacy Policy and Terms and Conditions.

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Elizabeth Johnson, LMFT RI lic#00029
Elizabeth Johnson, LMFT RI lic#00029
1 year ago

Unless Medicare provider qualifications have changed, only licensed social workers and psychologists can be reimbursed through Medicare. The exclusion of other licensed behavioral health care providers has been an issue throughout my 30 years in practice as a licensed marriage and family therapist. It often happens that when a patient receives Medicare, I can no longer continue working with him/her. This disruption in their continuity of care and loss of an established therapeutic relationship should not still be happening today in an environment of rigidly structured licensure requirements for each clinical discipline with across the board uniformity in education, coursework, clinical supervision, practicum, internship hours and CEUs. This is a tightly controlled political block to parity and the right for patients to have the freedom of choice to select the licensed provider of their choice

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