Telehealth.org: Q & A #20
Telehealth.org is continuing its Q&A series to address questions that it frequently receives. This week’s installment concerns a recently published blog post about a controversial reimbursement requirement for telemental health telehealth after the end of the public health emergency (PHE). Entitled Reimbursement Repercussions of April 2023, End of Public Health Emergency, the article raised several questions from readers who voiced concern over the mental health telehealth in-person visit requirement. Controversial since its announcement in 2020, the requirement was codified as part of the 2023 Physician’s Fee Schedule.
In February of 2022, Telehealth.org alerted the professional community that expanding Medicare reimbursement for telehealth from the Centers for Medicare & Medicaid Services (CMS) for video and audio services included an unpopular requirement for in-person meetings for telebehavioral health. The Senate Finance Committee at the time had been working on removing the in-person mandate. Their draft discussion document suggested that the Medicare requirement for in-person consultations would be removed and that audio-only mental health reimbursement would be permanent. The Committee was cited as stating that these changes are essential, calling them part of a “Bill of Rights.” See New Medicare Law Requires In-Person Visit for Telehealth Coverage for more information.
Current Medicare Mental Health Telehealth In-Person Visit Requirement
To the dismay of many telebehavioral health supporters, the requirement was officially codified in the 2023 Physician Fee Schedule – but it is not scheduled to be enacted for two years. Given the delay, it is unlikely to sustain the required two-year waiting period. As detailed in last week’s blog post, the current Physician’s Fee Schedule includes the following list of Medicare reimbursement approvals (note the in-person requirement’s date of enforcement):
- Medicare reimbursement for eligible telehealth services, including telebehavioral health, when the patient is located in a geographically rural area AND…