By Dr. Jackie Ward, OSTP Assistant Director for Community Connected Health
Throughout the COVID-19 pandemic, telehealth services have played an essential role in maintaining and expanding Americans’ access to their health care. But what comes next to ensure that telehealth can work after the pandemic? What can we learn from those with “hands-on” experience with telehealth from the past two years?
Health care providers have gathered essential data and insights from their experiences that could be valuable to the Federal Government in making future decisions about telehealth coverage and payment. The decisions about what is included on the Medicare telehealth services list are made based on the evidence submitted, and there are many researchers and clinicians out there who can contribute to this process:
We encourage medical professionals to share their recommendations on which telehealth services should be covered by Medicare. The process and criteria for submitting requests is available on the Medicare Telehealth webpage.
At the outset of the COVID-19 pandemic, the Department of Health & Human Services issued a formal, nationwide Public Health Emergency, known as a PHE, and issued emergency waivers for telehealth services under new authorities enacted by Congress. To ensure that Medicare beneficiaries would continue to receive care, CMS subsequently announced a number of temporary emergency waivers and regulatory flexibilities that allowed Medicare to pay for a wide range of telehealth services and allowed Medicare beneficiaries across the country to be able to receive telehealth services wherever they are located. The Biden-Harris Administration has committed to taking into account this national experience with telehealth during the PHE while ensuring a smooth transition for Medicare beneficiaries and health care providers once the PHE ends.
On November 1, CMS issued a final rule that announces 2023 policy changes for Medicare payments under the Physician Fee Schedule (PFS). This rule is issued every year to establish Medicare payment rates and policies for physicians and certain other medical professionals. This year’s rule is extensive with an overarching focus on the Biden-Harris Administration’s priority to create a more equitable health care system that results in better accessibility, quality, affordability, and innovation. The 2023 PFS rule finalizes some key policies related to Medicare telehealth services that have been available during the PHE:
- Some flexibilities are extended for an additional 151 days after the COVID-19 PHE ends (as consistent with recent legislation);
- Others will continue to be covered through the end of 2023 – these are services that may have a clinical benefit when furnished via telehealth, but CMS is in need of more evidence to determine permanent coverage; and
- A few have been permanently added to the Medicare telehealth services list, such as those related to chronic pain management or prolonged care evaluation and management.
This builds on prior rulemaking that permanently allows all Medicare patients to receive telehealth at home for mental health services. There are other Medicare policies and statutory limitations that affect payment for telehealth services – including limitations on the geographic and type of location where the patient receives the service, the modality used (e.g., audio-only or audio/video), and the type of health care professional who furnishes the telehealth service. These requirements are summarized at telehealth.hhs.gov.
The Medicare telehealth services list has a big impact on health care providers and beneficiaries. Now is the time to consider submitting requests and evidence for next year’s list!
CMS considers requests on an ongoing basis, but these requests must be submitted and received no later than February 10, 2023 to be considered for 2024. We have heard from many health care providers and health system administrators, including Federal health care providers at the Veterans Health Administration and the Military Health System, that they have shifted how they practice and deliver care to patients based on their experience with telehealth during the pandemic. We encourage researchers and healthcare providers to take advantage of this opportunity to inform government decision-making and contribute to Medicare’s telehealth policies.