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CMS has also released its CY 2024 Physician Fee Schedule (PFS) proposed rule. Alongside proposals on health equity and clinical quality, the rule expands and preserves certain telehealth flexibilities. It allows teaching physicians to continue using real-time audio/video technology through the end of CY 2024 and proposes to continue paying for telehealth services furnished in beneficiaries homes at the higher, non-facility PFS rate, until the end of CY 2024 as well. The Agency proposes a 3.34% decrease to the PFS conversion factor but a separate add-on payment for complex primary care visits and screening for social determinants of health. Comments on the proposed rule are due September 11^th. AHPA will release a detailed summary on all the proposals in the following Policy Brief. In the meantime, click here for CMS’ fact-sheet and keep reading for a deeper dive in the telehealth proposals.

• CMS proposes to extend payment parity for telehealth services provided in a patient’s home. Beginning in CY 2024, claims billed with POS 02 (Telehealth Provided Other than in Patient’s Home) would continue to be paid at the lower PFS facility rate. Claims billed with POS 10 (Telehealth Provided in Patient’s Home) would be paid at the higher PFS non-facility rate. Initially, flexibility was extended for coverage without originating site restrictions but payment parity was not.

 

• The Agency also proposes to extend telehealth payments related to mental and behavioral health for Rural Health Clinics (RHCs) and Federally-Qualified Health Centers (FQHCs) through the end of next year. Behavioral health services performed in these facilities would be able to be done under general supervision when provided “incident to” the physician or non-physician practitioner. Remote therapeutic and physiological monitoring, Community Health Integration, and Principal Illness Navigation services are proposed to be added for reimbursement under HCPCS code G0511.

 

• The rule also proposes to cover health and well-being coaching services and SDOH risk assessments being delivered through telehealth. These are currently not covered under Medicare and would be added to the Medicare Telehealth Services List on a temporary basis, while Social Determinants of Health (SDOH) risk assessments would be covered permanently. Elsewhere in the rule, CMS proposes allowing SDOH risk assessment to be added to the annual wellness visit as an option element for additional payment.

 

• The list of telehealth practitioners is amended to recognize marriage and family therapists and mental health counselors as telehealth practitioners, effective CY 2024.

 

• Frequency limitations would be removed for subsequent inpatient visits through the duration of CY 2024.

 

• Several proposals implement provisions of the Consolidated Appropriations Act of 2023. These include:
• Temporarily expanding originating sites to include anywhere within the U.S. that the beneficiary is located, including the person’s home;
• Expanding the definition of “telehealth practitioners” to include qualified audiologists, occupational therapists, physical therapists and speech-language pathologists.
• Delaying the requirement for an in-person visit within six months for those seeking mental health care via telehealth.