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.