The Centers for Medicare and Medicaid Services (CMS) has just unveiled an updated version of its Medicare Learning Network (MLN) fact sheet on Telehealth Services. This comes after a hiatus in updates due to the evolving landscape during the COVID-19 pandemic.
The revamped fact sheet reflects changes necessitated by the extension of many COVID-related telehealth flexibilities until December 31, 2024, following the passage of the Consolidated Appropriations Act, 2023. Key highlights from the updated fact sheet include:
- Until December 31, 2024, all patients can access telehealth services from any location, with no specific originating site requirements or geographic limitations.
- After December 31, 2024, some non-behavioral or mental telehealth services may reintroduce originating site requirements and geographic restrictions, but behavioral or mental telehealth remains accessible without such constraints under certain conditions.
- Eligible Medicare providers can continue offering distant site telehealth services until December 31, 2024.
- Audio-only telehealth can be used for select non-behavioral or mental telehealth services until December 31, 2024.
- CMS now mandates patient consent for all care management and virtual communication services, with consent obtainable when the services are initially provided.
- Beginning July 1, 2023, providers must report the use of telehealth technology in delivering home health services on relevant payment claims.
- Through December 31, 2024, telehealth can be used for hospice care eligibility recertification, and in some cases, behavioral or mental telehealth visits do not require in-person follow-ups within specific timeframes.
- CMS has extended the Acute Hospital Care at Home Program.
Notably, the revised fact sheet omits several elements from the prior version, including the permanent eligible originating site list and explanations related to rural patient requirements. Instead, it briefly mentions the possibility of reintroducing originating site requirements and geographic restrictions for non-behavioral or mental telehealth after December 31, 2024. This alteration aims to avoid confusion between current reimbursement policies (effective mostly until December 31, 2024) and permanent policies (slated for January 1, 2025), leaving room for potential amendments before the latter's implementation.
For comprehensive information on current Medicare telehealth policy, please consult the MLN Telehealth Services Factsheet. If you would like to become involved in ACA’s advocacy efforts, please contact the ACA Government Affairs and Public Policy team at firstname.lastname@example.org.