Medicare Telehealth Services in 2022

Question: Has the Medicare telemedicine list changed for 2022?

Answer: As the Centers for Medicare and Medicaid Services (CMS) continues to evaluate the inclusion of telehealth services that were temporarily added to Medicare’s list of telehealth services during the COVID-19 health emergency, they finalized that certain services added to the list of Medicare telehealth services will remain on the list until December 31, 2023.

This will allow CMS more time to assess whether each service should be permanently added to Medicare’s list of telehealth services.

CMS has finalized that they will extend, until the end of CY 2023, the inclusion on the Medicare Telehealth Services List of certain services temporarily added to the list of Telehealth Services that would otherwise have been removed from the list effective from the end of COVID-19 PHE or 31 Dec 2021. They have also extended the inclusion of some Cardiac and Intensive Cardiac Rehabilitation codes to the end of CY 2023. This will allow more time for CMS to collect data to decide whether or not each telehealth service will be permanently added to Medicare’s list of telehealth services.

Moreover, CMS adopts encoding and payment for longer virtual check-in service on a permanent basis.

Article 123 of the Consolidated Credits Act (CAA) removed geo-restrictions and added the beneficiary’s domicile as the authorized origin site for telehealth services provided for the diagnosis, assessment or treatment of a mental health disorder. Section 123 requires for these services that there be an in-person non-telehealth service with the physician or practitioner within six months prior to the initial telehealth service and an in-person non-telehealth visit must be provided at least every 12 days. months for these services.

Exceptions to the in-person visitation requirement may be made based on the recipient’s circumstances (with the reason documented in the patient’s medical record), and that more frequent visits are also permitted under policy, depending on clinical needs on a case-by-case basis.

CMS has modified the current definition of an interactive telecommunications system for telehealth services (which is defined as multimedia communication equipment comprising, at a minimum, audio and video equipment enabling real-time two-way interactive communication between the patient and the doctor remote site or practitioner) to include audio-only communication technology when used for telehealth services for the diagnosis, assessment or treatment of mental health disorders provided to established patients in their homes under certain circumstances.

CMS limits the use of an audio interactive telecommunications system only to mental health services provided by practitioners who have the ability to provide two-way audio/video communications, but where the recipient is unable to, or does not consent not to, the use of two-way audio/video technology.

CMS has also finalized a requirement for the use of a new modifier for services delivered using audio-only communications, which would serve to verify that the practitioner had the ability to provide two-way audio/video technology, but was instead using audio-only technology due to recipient choice or limitations. They also specify that mental health services may include treatment services for substance use disorders (TUS).

The new modifier – Modifier 93 – Synchronous telemedicine service rendered by telephone or other real-time interactive audio telecommunications system – is effective January 1, 2022.

“Synchronous telemedicine service” is defined as a real-time interaction between a physician or other qualified health professional (QHP) and a patient who is at a site remote from the physician or other QHP. All communication of information exchanged between the physician/QHP and the patient during the synchronous telemedicine service must be of sufficient quantity and nature to meet the key elements and/or requirements of the same service when it is rendered via face-to-face interaction.

Renee Dowling is a compliance auditor for Sansum Clinic, LLC, in Santa Barbara, California.

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