Dear Members,
Please keep in mind we are still reviewing what these changes mean for our members.
Today, the White House announced new changes to CMS regulations, including increased reimbursement and flexibility to bill for additional Medicare audio-only telehealth services, in certain circumstances.
Our preliminary review of the regulation indicates the following changes for the duration of the public health emergency:
- Increase in reimbursement for audio-only E/M codes: Previous guidance permitted billing for audio-only telehealth visits for certain CPT codes, including virtual check-ins and some evaluation and management codes. CMS is now increasing payments for specified E/M telephone encounters to match payments for similar office and outpatient visits. This would increase payments for these services from a range of about $14-$41 to about $46-$110. The payments are retroactive to March 1, 2020.
- Expansion of audio-only billing for Opioid Treatment Programs (OTPs): Previous guidance permitted therapy and counseling to take place via audio-only telehealth in OTPs. OTPs will now be able to do periodic assessments via audio-only calls.
- Expansion of telehealth for partial hospitalization programs: In the context of hospital and outpatient partial hospitalization programs, individual psychotherapy, patient education, and group psychotherapy can now be billed as telehealth visits, including via audio-only encounters when audio/video technology is not available. All other PHP requirements remain unchanged, including that all services furnished under the PHP still require an order by a physician, must be supervised by a physician, and others. These encounters may take place with the patient in their own home.
The National Council continues to analyze the rule and its implications for our members, and will provide more information. In the meantime, the Interim Final Rule can be found here: https://www.cms.gov/files/document/covid-medicare-and-medicaid-ifc2.pdf.
For additional information, please visit our COVID-19 resource site: https://www.thenationalcouncil.org/covid19/
Questions? Please send them to policy@thenationalcouncil.org
Thank you,
Frankie
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Frankie Berger
Director, State Policy and Advocacy
National Council for Behavioral Health
202-684-3727
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