Behavioral Health Services
During the PHE, Medicare expanded coverage of behavioral health services via telehealth. For example, Medicare allowed Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) to provide behavioral health services via telehealth as distant site providers, waived geographic and location restrictions for originating sites for behavioral health services, and permitted audio-only communication platforms for behavioral health services.
Some of these changes are permanent or extended until December 31, 2024. However, some changes will expire when the PHE ends. For example, Medicare will revert to its pre-PHE list of telehealth services, which means that some behavioral health codes that were added during the PHE will no longer be covered by Medicare via telehealth. Also, Medicare will reinstate the requirement for an in-person visit within six months of an initial behavioral health telehealth service, and annually thereafter, with any provider of the same group and specialty.
Place of Service Codes
During the PHE, Medicare instructed providers to use place of service (POS) code 11 (office) for telehealth services provided to patients in their homes or other locations, instead of POS code 02 (telehealth), which would normally apply for telehealth services. This was done to ensure that providers would receive the same payment rate for telehealth services as they would for in-person services.
Medicare also created a new POS code 10 (temporary lodging) for telehealth services provided to patients who are temporarily located outside their home state or county due to a federally declared emergency or public health emergency.
These changes will remain in effect until December 31, 2024. After that date, Medicare will resume using POS code 02 for telehealth services and discontinue using POS code 10.
During the PHE, Medicare allowed certain telehealth services to be delivered using audio-only communication platforms when the patient does not have the ability for audio and video. This was especially helpful for patients who had limited access to technology or internet connectivity.
This allowance will also expire when the PHE ends, except for behavioral health services, which can continue to be delivered using audio-only platforms until December 31, 2024.
Teaching Physician Supervision
During the PHE, Medicare allowed teaching physicians to virtually supervise residents using real-time audiovisual communication when they provide telehealth services to Medicare beneficiaries until the end of the PHE.
This change will also expire when the PHE ends, except for telehealth services provided by residents in rural areas, which can continue to be virtually supervised by teaching physicians after the end of the PHE.
During the PHE, Medicare allowed nurse practitioners (NPs) and physician assistants (PAs) to provide and bill for telehealth services under the direct supervision of a physician who is virtually present using real-time audiovisual communication until the end of the PHE.
This change will also expire when the PHE ends. After May 11, 2023, NPs and PAs will need to bill for telehealth services under their own enrollment or under the general supervision of a physician who is not required to be virtually present.
Telehealth has been a lifeline for many patients and providers during the COVID-19 pandemic. But not all telehealth changes that were implemented during the PHE will last forever. Some will expire when the PHE ends on May 11, 2023, while others will continue until December 31, 2024 or beyond. To stay updated on telehealth policy changes, please visit https://telehealth.hhs.gov/ and https://www.cms.gov/.