2022 CMS Physician Fee Schedule Final Rule to Support Access to Telehealth

While the process of evaluating whether certain telehealth services that were added during the COVID-19 public health emergency should be permanently included in the Medicare telehealth services list is still ongoing, such services will remain on the list until December 31, 2023, when the final decision is expected. The same applies to certain cardiac and intensive cardiac rehabilitation codes, which will also be preserved until 2023. In addition, CMS permanently adopted codes and payments for longer virtual check-in services.

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Congress urged to expand Telehealth Options for Employees

On November 1st, 2021, the American Telehealth Association and nearly 50 other organizations have written a letter to Congress requesting that the temporary pandemic regulations pertaining to telehealth services be made permanent and categorized as an excepted benefit for certain employees.

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Remote patient monitoring drives high patient engagement

Remote patient monitoring has been around for some time now. However, the COVID-19 pandemic has highlighted the benefits of remote monitoring in patient care and helped many chronic disease patients that did not have traditional access to their providers manage their conditions from the comfort of their homes.

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Time is right for providers to evaluate RPM

COVID-19 pandemic has influenced the rapid adoption of telehealth by providers across the country. During these times many providers were forced to completely switch to telehealth. Both providers and their patients experienced the benefits of telehealth.

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Role of telehealth in serving the aging population

The population of the U.S. is aging. Today, there are more than 46 million adults aged 65 and over – which makes up roughly 14% of our population.1 This number is expected to keep growing rapidly and reach 22% by the year 2050. This is a significant increase from the 1950s when only 8% the of the population was 65 and over.1 In this decade, the last of the baby boomers will reach the age of 65, and it is projected that by 2030 1 in 5 people in the U.S. will be 65 and over.2

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Asynchronous Consultations available through Vivabot

During the COVID-19 public health emergency different modes of telehealth have become rapidly adopted and utilized to provide adequate care to the millions of patients across the country. For many, the first thought when the word telehealth is mentioned is a live video interaction between the provider and the patient. However, telehealth understands many different technologies and tools that can help deliver care

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ATA Comments on CMS 2022 PFS Proposed Rule

On September 1st, 2021, American Telemedicine Association (ATA) has submitted and shared their response to the Centers for Medicare and Medicaid 2022 Physician Fee Schedule proposed rule. In the submission, they provided valuable comments to some of the key items including the in-person requirement for certain telemental health services, allowing additional providers to provide telehealth services to eligible patients, appropriate technologies that can be used to access and provide telehealth services, an extension of Category 3 services, and remote physiological and therapeutic monitoring.

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CMS telehealth proposed coverage expansion

During the pandemic, many patients and providers got a chance to experience the benefits of telehealth. While this opportunity was enabled by the loosened regulations due to the state of emergency, the future and application of telehealth and remote patient monitoring is now in the hands of the healthcare lawmakers that determine reimbursement policies.

In the 2022 Physician Fee Schedule, the Centers for Medicare and Medicaid Services proposed an extension of most of the COVID-19 relaxations until the end of 2023. Such extension would allow for sufficient time to assess which services should be permanently kept after the public health emergency. In addition, the proposal extends coverage for telehealth sessions treating substance abuse and mental health issues.

The other proposed changes include the elimination of geographical restrictions, allowing the patient’s home to be the originating site for the mental health video telehealth coverage, with a requirement that there is at least one in-person visit every six months. When it comes to audio-only telehealth, CMS proposed changes to their previous requirements. If passed, these changes would allow for audio-only telehealth to be used for mental health diagnosis, evaluation, and treatment.

“CMS is proposing to limit the use of an audio-only interactive telecommunications system to mental health services furnished by practitioners who have the capability to furnish two-way, audio/video communications, but where the beneficiary is not capable of using, or does not consent to, the use of two-way, audio/video technology,” the agency said. “CMS is also proposing to require the use of a new modifier for services furnished using audio-only communications, which would serve to certify that the practitioner had the capability to provide two-way, audio/video technology, but instead, used audio-only technology due to beneficiary choice or limitations.”1

CMS also proposed expansion of Medicare coverage for real-time mental health telehealth treatment provided by FQHCs (Federally qualified health centers) and RHCs (Rural health clinics). As of right now, neither FQHCs nor RHCs have been listed as distant site telehealth providers. Such expansion of Medicare coverage can make a tremendous difference for underserved populations.

Expansion of RPM (Remote patient monitoring) coverage is still being discussed.

“Notably, the current proposal does not include any changes to the use of RPM CPT codes. This comes as a disappointment to many who had hoped CMS would remedy the limitations imposed by the 16 days’ transmission requirement,” states Carrie Nixon in a blog.4

However, the 2022 Physician Fee Schedule includes a new category of CPT codes called “remote therapeutic monitoring”.  The new RTM codes with previously introduced RPM codes give healthcare providers more options for reimbursement. This proposal has greatly expanded what was understood by RTM, however, there are still plenty of unknowns and details that need to be clarified. It is expected that these unknowns will be clarified in the upcoming months so that the providers can confidently plan to implement or enhance existing telehealth and remote patient monitoring offerings.

Any feedback on the 2022 Physician Fee Schedule propositions must be submitted by September 13th, 2021.


1. https://mhealthintelligence.com/news/cms-expands-telehealth-coverage-in-proposed-2022-physician-fee-schedule?eid=CXTEL000000638360&elqCampaignId=20198&utm_source=nl&utm_medium=email&utm_campaign=newsletter&elqTrackId=22d95a823e30476eb9285afd2181c205&elq=56965d0907f54d13b90e6f12132cb6a8&elqaid=21080&elqat=1&elqCampaignId=20198

2. https://mhealthintelligence.com/news/cms-expands-remote-patient-monitoring-coverage-in-proposed-2022-pfs?eid=CXTEL000000638360&elqCampaignId=20251&utm_source=nl&utm_medium=email&utm_campaign=newsletter&elqTrackId=6070d455d7ea47f58c700d912dab4057&elq=e3ab24d69eb1434da87ad6c4aee4dcb6&elqaid=21086&elqat=1&elqCampaignId=20251

3. https://www.physicianspractice.com/view/remote-therapeutic-monitoring-s-debut-what-you-should-know-for-now-

4. https://nixongwiltlaw.com/nlg-blog/2021/7/14/new-remote-therapeutic-monitoring-cpt-codes-introduced-in-proposed-2022-medicare-physician-fee-schedule