2023 Physician Fee Schedule - Telehealth Changes
As of November 1st, the Centers for Medicaid and Medicare Services (CMS) has released the updated Physician Fee Schedule for 2023. The annual Physician Fee Schedule determines which services will be covered by Medicare next year. There are several changes to telehealth for 2023 – we will be covering the most significant of those changes here.
Public Health Emergency (PHE) Temporary Extension
The 2023 Physician Fee Schedule will allow a temporary extension on certain services beyond the end of the PHE. The services allowed via telehealth under the PHE that have not been made permanent or extended in another way (i.e., given Category 3 status) will be discontinued 151 after the end of the PHE. Their temporary telehealth codes will no longer be covered after this extension ends.
Extended Coverage for Select Services
Several services made temporarily available during the PHE will continue to be allowed through the end of 2023 as “Category 3” services. CMS acknowledges the clinical benefit of these services when provided via telehealth but, at this time, does not have the evidence to support adding them permanently. This might change if further evidence is gathered, but these codes have been extended only through the end of 2023.
Fifty-four codes have been added to Category 3, which will be covered via telehealth at least the end of 2023. They are primarily related to behavioral health and audiology.
Telephone (audio-only) Evaluation and Management (E/M) Services
Under the public health emergency (PHE), audio-only E/M services (CPT codes 99441-99443) were allowed for separate reimbursement by CMS. Following the end of the PHE, this will no longer be allowed. 151 days after the expiration of the PHE, audio-only E/M services will no longer be separately reimbursable and will revert to their status from before the PHE - covered but not separately payable, also known as “provider-liable” or “bundled.”
Some exceptions will be made for certain tele-behavioral health services.
Virtual Direct Supervision
During the PHE, CMS allowed direct supervision required under Medicare to occur virtually. CMS had decided not to make this change permanent – as of the 2023 Physician Fee Schedule, direct virtual supervision will be allowed through the end of the year in which the PHE expires. Because the PHE will expire in January 2023 at the earliest, direct virtual supervision will be allowed through the end of 2023 but is not expected to continue beyond that.
Tele-behavioral Health Six-Month Rule
Under Medicare, behavioral health services may be provided via telehealth when the following conditions are met:
- The patient has had an in-person appointment within six months of the initial telehealth service
- The appointment is for the diagnosis, evaluation, or treatment of a mental health disorder (other than for treatment of a diagnosed substance use disorder (SUD) or co-occurring mental health disorder)
- The provider has one appointment in-person every 12 months.
These restrictions were initially expected to begin again immediately following the end of the PHE. That has been changed – these restrictions will now come into effect 151 days following the end of the PHE.
The Physician Fee Schedule for 2023 reflects that there are still many things to be determined about the future of telehealth. The end of the PHE and many telehealth flexibilities is expected to occur in January of 2023, but that is subject to change. The 151-day grace period following the end of the PHE will allow providers to transition away from services that are no longer covered outside of the PHE, while the extended coverage of “Category 3” services will allow for the continued use of services that have proven effective during the pandemic until at least the end of 2023.
This write-up is intended to be informational – for a complete understanding, see the full list of telehealth services allowed by the 2023 Physician Fee Schedule.
Comments
0 comments on "2023 Physician Fee Schedule - Telehealth Changes"
Leave a Comment