Temporary and Emergency Changes to Medicare’s Payment of Virtual Services
Alert by David Givens
The Centers for Medicare & Medicaid Services (CMS) is expanding access to telehealth services on a temporary and emergency basis retroactive to March 1, 2020. Telehealth, or Telemedicine, refers to the exchange of medical information from one site to another through electronic communication to improve a patient’s health. During the COVID-19 pandemic, individuals can use commonly available interactive apps to visit with their clinicians. Importantly, any technology with audio and video can be used, meaning people with Medicare can receive care at home or in a nursing or assisted living facility. Telehealth will allow suspected and confirmed COVID-19 patients to remain in isolation and prevent spreading the virus. It will also allow Medicare patients who are not infected to get care without possible exposure.
Practitioners who can furnish and get payment for covered telehealth services, subject to state law, include physicians, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, clinical social workers, registered dieticians, and nutrition professionals. In addition, CMS is allowing physicians to supervise their clinical staff using virtual technologies when appropriate. Medicare beneficiaries can receive specified services through telehealth, including evaluation and management visits, common office visits, mental health counseling, and preventive health screenings. Telehealth visits may also include emergency department visits, initial nursing facility and discharge visits, home visits, and therapy services, which must be provided by a clinician authorized to provide telehealth. New patients may now stay at home and have a telehealth visit with their provider.
CMS is also allowing telehealth to fulfill many face-to-face visit requirements for clinicians to see their patients in inpatient rehabilitation facilities, hospice, and home health. CMS also permits clinicians to provide remote physiologic monitoring services to patients with acute and chronic conditions. For example, CMS is permitting remote monitoring of a patient’s oxygen saturation levels using pulse oximetry.
Home health agencies can also provide more services to beneficiaries using telehealth, as long as it is part of the patient’s Plan of Care and does not replace needed in-person visits as ordered on the Plan of Care. If a physician determines that a Medicare beneficiary should not leave home because of a medical contraindication, or due to suspected or confirmed COVID-19 infection, and the beneficiary needs skilled services, he or she will be considered homebound and qualify for the Medicare Home Health Benefit. As a result, the beneficiary can receive services at home. Hospice providers can also provide services to a Medicare patient receiving routine home care through telehealth if it is feasible and appropriate to do so.
CMS maintains a list of services that are normally furnished in person that may be temporarily furnished via Medicare telehealth. This list can be found at https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes
Disclaimer – This article was prepared as an educational document and is not intended as legal advice. The information provided is only a general overview and is not intended to take the place of either the written law or regulations. Readers are encouraged to review the specific statutes, regulations and other interpretive materials published by CMS for a full understanding of their contents.