CMS COVID-19 Interim Final Rule Summary and Code Chart

Posted Alliance for Connected Care Articles, COVID-19

As part of its announcement on “Sweeping Regulatory Changes to Help U.S. Healthcare System Address COVID-19 Patient Surge the Administration included significant additional Medicare telehealth changes, including:

  • CMS will now pay for more than 80 additional services when furnished via telehealth. These include emergency department visits, initial nursing facility and discharge visits, and home visits, which must be provided by a clinician that is allowed to provide telehealth.
  • CMS finalized CPT codes 98966-98968 and CPT codes 99441-99443 for prolonged, audio-only communication between the practitioner and the patient.
  • Virtual Check-In services, or brief check-ins between a patient and their doctor by audio or video device, could previously only be offered to patients that had an established relationship with their doctor. Now, doctors can provide these services to both new and established patients.
  • Clinicians can provide remote patient monitoring services for patients, no matter if it is for the COVID-19 disease or a chronic condition. For example, remote patient monitoring can be used to monitor a patient’s oxygen saturation levels using pulse oximetry.
  • CMS is allowing telehealth to fulfill many face-to-face visit requirements for clinicians to see their patients in inpatient rehabilitation facilities, hospice and home health. During the pandemic, individuals can use commonly available interactive apps with audio and video capabilities to visit with their clinician.
  • Home Health Agencies can provide more services to beneficiaries using telehealth, so long as it is part of the patient’s plan of care and does not replace needed in-person visits as ordered on the plan of care.
  • Hospice providers can also provide services to a Medicare patient receiving routine home care through telehealth, if it is feasible and appropriate to do so.
  • If a physician determines that a Medicare beneficiary should not leave home because of a medical contraindication or due to suspected or confirmed COVID-19, and the beneficiary needs skilled services, he or she will be considered homebound and qualify for the Medicare Home Health Benefit. As a result, the beneficiary can receive services at home.
  • CMS is allowing for physician supervision requirements to be provided virtually, using real-time audio/video technology.  Other changes to supervision requirements as well.
  • Licensed clinical social worker services, clinical psychologist services, physical therapy services, occupational therapist services, and speech language pathology services can be paid for as Medicare telehealth services.

Please find a more detailed summary and a chart of the newly covered services below.

*Note that this interim final rule does not reflect several of the statutory changes achieved for telehealth in the “Coronavirus Aid, Relief, and Economic Security Act,” which was signed into law on March 27. That law altered preexisting relationship requirements for telehealth in Medicare and altered the telehealth payment structure for Federally Qualified Health Centers — among other changes.

For information on the COVID-19 waivers and guidance, and the Interim Final Rule, please go to CMS COVID-19 flexibilities webpage: https://www.cms.gov/about-cms/emergency-preparedness-response-operations/current-emergencies/coronavirus-waivers.

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