Telehealth in a Post-COVID World: What You Need to Know

The U.S. Department of Health and Human Services expects COVID-19 to expire as a public health emergency (PHE) on May 11, 2023. As the pandemic continues to slow down, telehealth plays a pivotal role in the healthcare landscape where it has helped support healthcare providers and patients.

Several of the Medicare telehealth flexibilities allowed during the COVID-19 PHE have been made permanent, while others are temporary. Below is a summary of some of the key changes to telehealth policies to be aware of during this transitional period:

Permanent Medicare Changes

• Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) can now serve as distant site providers for behavioral/mental telehealth services.
• Medicare patients can access behavioral/mental telehealth services from the comfort of their homes.
• There are no longer geographic restrictions for originating sites for behavioral/mental telehealth services.
• Audio-only communication platforms can be used to deliver behavioral/mental telehealth services.
• Rural hospital emergency departments are now accepted as originating sites.

Temporary Medicare Changes (Until December 31, 2024)

• FQHCs/RHCs can serve as distant site providers for non-behavioral/mental telehealth services.
• Medicare patients can receive telehealth services authorized in the Calendar Year 2023 Medicare Physician Fee Schedule at home.
• There are no geographic restrictions for originating sites for non-behavioral/mental telehealth services.
• Some non-behavioral/mental telehealth services can be delivered using audio-only communication platforms.
• An in-person visit is not required within six months of an initial behavioral/mental telehealth service and annually thereafter.
• Telehealth services can be provided by physical therapists, occupational therapists, speech-language pathologists, or audiologists.

IMPORTANT NOTE: The flexibility allowing these clinician types (PT, OT, SLP and audiologists) to provide telehealth services until 12/31/2024 may be dependent upon where you practice, and the claim form used for billing. Stakeholders are awaiting further clarification from CMS. You should work with your professional organizations to help determine when your telehealth flexibilities end.

Temporary Changes (Until the End of the COVID-19 Public Health Emergency)

• Telehealth can be provided as an expected benefit.
• Medicare-covered providers can use non-public facing applications for patient communication without risking federal penalties, even if the application isn’t compliant with the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

As the healthcare industry adapts to the evolving telehealth landscape, stay up to date with the latest information on the Centers for Medicare & Medicaid Services (CMS) website. Embracing these changes will allow healthcare providers to continue delivering quality care and improve patient access to vital services in a post-COVID world.

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Disclaimer: The information contained in this blog is a summary and intended for educational purposes only. Interpretation of regulations and any guidance should be reviewed with your legal and compliance teams for applicability to your practice or organization.

References:

Telehealth HHS.gov, “Telehealth Policy Changes After the COVID-19 Public Health Emergency,” April 26, 2023.