Calendar Year 2024 Physician Fee Schedule Final Rules – Telehealth Codes

The 2024 Medicare Telehealth Services document lists Medicare telehealth codes that are provisional and permanent for the 2024 calendar year.

Telehealth PHE Expansions to Continue 151 Days Post-PHE (Center for Connected Health Policy)

On March 15^th President Biden signed the Consolidated Appropriations Act of 2022.  This bill will extend federal telehealth flexibilities for 151 days post-public health emergency (PHE), including PHE location, provider, and audio-only expansions, and includes new report requirements. A delay to the new in-person telemental health visit requirement in Medicare was also included for the same period of time.

The telehealth components in the legislation include:

• Telehealth Flexibility Location – Geographic & rural exceptions to allow for any site including the home to continue for 151 days after the PHE ends – no facility fee for these sites
• Telehealth Flexibility Provider Type – Adds occupational therapists, physical therapists, speech-language pathologists, audiologists, and federally qualified health centers (FQHCs) and rural health clinics (RHCs) to eligible provider list for 151 days
• Audio-Only – Continue to allow for the 151-day extension period
• In-person visit requirement for telemental health – Delay requirement until after the 151 days extension
• Use of telehealth for recertification of eligibility for hospice care – Continue to allow for the 151-day extension period
• New Reports
  • MedPAC report due June 15, 2023 to Congress, includes looking at payment policy for telehealth for FQHC and RHCs
  • Beginning July 1, 2022, Secretary of Health and Human Services must publicly publish on quarterly basis data on Medicare claims on telehealth services including utilization and beneficiary characteristics
  • By June, 15, 2023, Office of Inspector General to submit to Congress fraud, waste, and abuse report on program integrity

Funding opportunities that could be put toward telehealth are also included in the legislation, including funding for rural hospital programs and telehealth networks, in addition to grants that will establish or sustain mobile teams or enhance access through telehealth.

While the resources and extensions in the agreement are promising, they signify that conversation around permanent telehealth policies are far from over. For more information, please review the Consolidated Appropriations Act of 2022 in its entirety. For a helpful breakdown of the bill and its telehealth components, access CCHP’s Consolidated Appropriations Act of 2022 Chart.

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Billing and Policy Help

• Updated 2023 CCHP Telehealth Billing Guide
• Telehealth Services and Codes (NRTRC)
• CMS Telehealth Payment Rules
• WyTN 3-Part Series on Telehealth Billing (January, February, and March Webinars)

COVID-19 Expanded Benefits for Telehealth Services

• CMS Coronavirus Partner Virtual Toolkit
• Medicare Telemedicine Health Care Provider Fact Sheet
• Medicare Telehealth FAQ
• Coronavirus.gov

Policy Documents

• Zoom Business Associate Agreement
• Wyoming Telehealth Policy
• Wyoming Medicaid Telehealth Billing Information
• American Hospital Association – Special Bulletin – CMS Releases Final Rule for CY 2017 Physician Fee Schedule
• HIPAA & Telehealth: A Stepwise Guide to Compliance
• State Telehealth Laws and Medicaid Program Policies: A Comprehensive Scan of the 50 States and District of Columbia
• MACRA & Implications for Telemedicine
• Telehealth Services: Medicare Fee-For-Service Program
• CMS Telehealth Payment Rules
• Board of Pharmacy Chapter 14: Telepharmacy
• Wyo Statute 33-24-156: Telepharmacy Practice Authorized
• Contract Year (CY) 2020 Medicare Advantage and Part D Flexibility Proposed Rule (CMS-4185-P)

Center for Telehealth & e-Law

• Telehealth Credentialing and Privileging Final Rule from CMS
• Check List – Telehealth Credentialing and Privileging Sec. 482.22. Conditions of Participation – Medical Staff
• Check List – Telehealth Credentialing and Privileging Sec. 482.12. Conditions of Participation – Governing Body
• Check List – Telehealth Credentialing and Privileging Sec. 485.616. Conditions of Participation –Agreements for Critical Access Hospitals
• Check List – Telehealth Credentialing and Privileging Sec. 485.635. Condition of participation: Critical Access Hospitals (CAHs). Provision of Services
• Conditions of Participation for Hospitals and Critical Access Hospitals Original Requirements and Changes Resulting from Telehealth Final Rule
• Physician Credentialing and Privileging Agreement Between Hospitals Template
• Physician Credentialing and Privileging Agreement Between Telemedicine Entity & Hospital Template