- FAQs on CMS Waivers, Flexibilities, and the End of the COVID-19 PHE.
- Fact Sheet: What Do I Need to Know? CMS Waivers, Flexibilities, and the Transition Forward from the COVID-19 Public Health Emergency
- FAQs on CMS Waivers, Flexibilities, and the End of the COVID-19 PHE
- CMS Current Emergencies Web Page
- CCHP (Center for Connected Health Policy): Cross-State Licensing (Telehealth)
Let’s talk about Telehealth
Let’s talk about Telehealth. Telehealth burst onto the seen like never before at the start of the PHE (Public Health Emergency). The changes in coding, billing, and documentation guidelines seemed to change daily. CMS has slated the end of the PHE as May 11, 2023. Some services will be available through December 2023, others through December 2024 due to the CAA (Consolidated Appropriations Act).
There are three types of telehealth services: Asynchronous, Synchronous, and Remote Patient Monitoring. Each type is connected to specific billing and reimbursement rules. The HHS (Human Health Services) has put together a fantastic billing tip sheet that outlines how to report telehealth/telemedicine services at the federal, state, and private payer level.
Additionally, the TMA released an at-a-glance telehealth chart outlining what’s staying and what’s going at the end of the PHE here.
Expiring December 31, 2024 (CAA):
- Audio Only – The Centers for Medicare & Medicaid Services (CMS) allows certain audio-only services.
- Originating Site – Patients in a rural area no longer must receive services at an originating site.
- Provider Types – Physical therapists, occupational therapists, and speech pathologists are authorized to
provide telehealth services.
Expiring December 31. 2023:
- Essentially, everything else will expire after the 151-day grace period after the PHE ends on May 11, 2023.
The special waivers that allowed for supervision via A/V technology, special (POS) Places of Service, and telehealth technology use requirements (and others) revert back to pre-pandemic guidance. Please make sure to familiarize yourself with the TMA telehealth timelines.
Texas HHS has made available a short 12″ course for CME credit titled Texas Medicaid Telemedicine and Telehealth Services for Children and Adolescents here.
NOTE: You must be a part of the Interstate Medical Licensure Compact in order to provide telehealth services across state lines. Please visit the Texas Medical Board Interstate Licensure page for more information.
International Telemedicine follows the same guidance as the Interstate Medical Licensure Compact in that you must be licensed in the country where your patient resides. CHUBB has released a handy best practice check list.
Telehealth Resource Links:
July 2023 CCHPC Final Billing Guide
Best Provider Practices for Telehealth (HHS)
Billing for Telehealth During PHE (HHS)
Chronic Conditions Billing (HHS)
Prescribing Controlled Substances after the PHE ends
End of PHE Resource Links:
If you have a question regarding the end of the PHE or Telemedicine, please reach out to your departmental compliance liaison, Jay.McVean@uth.tmc.edu, or Caroline.Wolbrecht@uth.tmc.edu.