Navigating Telehealth and Telemedicine Reimbursement Post-PHE

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The Public Health Emergency is Over Now What?
Digital Health Updates

• Presented By
• Toni Elhoms, CCS, CPC, CPMA, CRC, AHIMA-Approved
  ICD-10-CM / PCS Trainer

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Toni Elhoms, CCS, CPC, CPMA, CRC, AHIMA Approved
ICD-10-CM/PCS Trainer

• CEO Alpha Coding Experts
• Podcast Host Alpha Coding Podcast
• National Speaker - Coding, Compliance and
  Reimbursement SME
• Former President of Orlando, Florida AAPC
  Chapter
• Expert Witness
• Published Author
• Consultant/Educator/Trainer

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Agenda
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Telehealth Services

• Service must be furnished via an interactive
  telecommunications system
• Service must be furnished by a physician or
  authorized non-physician practitioner
• Service must be furnished to eligible telehealth
  patient
• Patient must be in an approved Telehealth
  original site

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Telehealth Eligible Providers

• Physicians
• Nurse Practitioners (NPs)
• Physician Assistants (PAs)
• Nurse Midwives (CNMs)
• Clinical Nurse Specialists (CNS)
• Certified Registered Nurse Anesthetists (CRNAs)
• Clinical Psychologists (CPs)
• Clinical Social Workers (CSWs)
• Registered Dieticians and Registered
  Nutritionists

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Telehealth Eligible Facilities

• Office
• Hospital
• Critical Access Hospitals (CAHs)
• Rural Health Clinics (RHCs)
• Federally Qualified Health Centers (FQHCs)
• Hospital or CAH Renal Dialysis Centers
• Skilled Nursing Facilities (SNFs)
• Community Mental Health Centers (CMHCs)

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Latest Digital Health Updates

• COVID-19 Public Health Emergency (PHE) ended on
  May 11, 2023
• Consolidated Appropriations Act (CAA) of 2023
  extended certain telehealth flexibilities through
  12/31/2024
• Providers eligible to bill Medicare can bill for
  TH services regardless of where the patient is
  located
• Audio-only telehealth visits will continue to be
  reimbursed
• Physical Therapists, Occupational Therapists,
  Speech Therapists can bill for TH until 12/31/23

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Latest Digital Health Updates

• For Medical Telehealth originating site
  restrictions are extended through 12/31/2024
• For Behavioral Health Telehealth originating
  site restrictions are permanently waived
• Higher reimbursement rates will end at the end of
  2023
• Separate fee schedules for TH services
• Federally Qualified Health Centers (FQHCs) and
  Rural Health Clinics (RHCs) can provide
  telehealth services to Medicare beneficiaries
  (i.e., can be distant site providers), rather
  than being limited to being an originating site
  provider for telehealth (i.e., where the
  beneficiary is located)

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Originating Site

• Location of the facility where the patient is
  located at the time the service is provided via a
  telecommunications system
• Telepresenters may be needed to facilitate the
  delivery of this service
• Commonly referred to as Spoke Site

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Distant Site

• Site at which the physician or other licensed
  practitioner delivering the service is located at
  the time the service is provided via
  telecommunications system
• Temporary relaxation on distant site
  requirements that providers must be at their
  office/hospital location
• Enrollment forms will need to be updated to
  include Telehealth rendering providers home
  address

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Parity Laws
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Best Practice Tips
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Resources

• American Medical Association (AMA)
• Center for Connected Health Policy
• CMS.gov
• Congress.gov
• FCC.gov
• HHS.gov
• Noridian

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