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CMS Expands Medicare Telehealth Coverage for Mental Health and Addiction Treatment Services

The Centers for Medicare & Medicaid Services (CMS) extended some Medicare coverage of telehealth services that the agency authorized during the Covid-19 pandemic. The changes were included in the final 2021 Medicare Physician Fee Schedule rule that was published in the Federal Register on Dec. 28, 2020.

Extended Coverage of Certain Services

CMS permanently extended Medicare coverage of the following services provided via telehealth:

  • Home Visits, Established Patients (only for treatment of substance use disorders (SUDs) and co-occurring mental health disorder when less complex, lasting typically 25 minutes) (99347 & 99348),
  • Group Psychotherapy (other than of a multiple-family group) (90853),
  • Psychological and Neuropsychological Testing (96121),
  • Care Planning for Patients with Cognitive Impairment (99483),
  • Domiciliary, Rest Home, or Custodial Care services (99334),
  • Domiciliary, Rest Home, or Custodial Care services (99335),
  • Visit Complexity with certain office/outpatient evaluation and management services (G2211),
  • Prolonged office or other outpatient evaluation and management service(s) (G2212), and
  • New codes for the initial month or subsequent months of psychiatric collaborative care model services (G2214).

CMS also finalized a long list of telehealth services that are covered temporarily until the end of the calendar year in which the public health emergency (PHE) ends. Here are some examples:

  • Home Visits, Established Patients (only for the treatment of substance use disorder or co-occurring mental health disorder when moderate to severe, typically lasting 60 minutes) (99349, 99350),
  • Psychological and Neuropsychological Testing (96130- 96133, 96136- 96139),
  • Therapy Services, Physical, and Occupational Therapy (97161-97168, 97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761, 92521- 92524, 92507),
  • Emergency Department Visits (99281-99285),
  • Domiciliary, Rest Home, or Custodial Care services, Established patients (99336 & 99337),
  • Initial Hospital Care and Hospital Discharge Day Management (99221-99223, 99238, 99239), and
  • Subsequent Observation and Observation Discharge Day Management (99217, 99224-99226).

CMS said it intends these temporary extensions of coverage to allow time for the agency to consider whether these services should be extended permanently.

Special Coverage of Mental Health and Substance Use Disorder Treatment via Telehealth

This rule implements a change in the Medicare statute enacted in the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act) authorizing Medicare coverage as of July 2019 of telehealth visits in a patient’s home (instead of a healthcare facility that qualifies as originating site) and regardless of whether the patient lives in a rural area, but only for treatment of substance use disorders (SUDs) and co-occurring mental illnesses. This final rule states that permanent Medicare coverage of home visits for treatment of SUDs and co-occurring mental health conditions is limited to established patients with less complex conditions. Medicare coverage of home visits via telehealth for moderate to severe SUDs or co-occurring mental illnesses will be covered temporarily until the end of the calendar year in which the PHE ends.

CMS also finalized regulations allowing periodic assessments, which are part of opioid use disorder treatment services for opioid treatment programs, to be furnished via two-way interactive audio-video communication technology, as clinically appropriate, if all other applicable requirements are met.

With a late-breaking addition, the FY 2021 Appropriations and Covid-19 Relief legislation enacted into law on Dec. 27, 2020 includes a provision authorizing Medicare coverage of mental health services via telehealth to beneficiaries in their homes regardless of geographic location. This provision adds mental health to the existing Medicare coverage authorized in the SUPPORT Act of telehealth services for beneficiaries in their homes, regardless of geographic location, to treat SUDs and co-occurring mental health conditions. The new law adds a requirement that a provider must have seen the beneficiary within six months before receiving the telehealth service to treat a mental health condition. The provision in the latest Covid-19 Relief legislation also states that the Health and Human Services (HHS) secretary may implement this section by interim final rule or “program instruction.” NABH will advise members when HHS takes action to implement the important provision.

Coverage of Audio-only and Some Other Services Not Extended

Medicare will no longer cover audio-only telehealth visits by physicians (99441-99443) and non-physician practitioners (98966-98968) after the PHE ends. CMS explained that its longstanding interpretation of the statutory provision that authorizes coverage of telehealth refers use of an “interactive telecommunication system” that CMS interprets to exclude audio-only technology.

However, CMS did create a new code (G2252) to be used for coverage of longer virtual check-ins (11 to 20 minutes of medical discussion when the acuity of the patient’s problem is not likely necessary to warrant a visit, but the needs of the patient require more assessment time from the practitioner). This new code is valued at the same rate as 99442, whereas the pre-existing virtual check-in service (G2012) is valued at the rate of 99441.

Telehealth visits will also no longer be covered for the initial visit with patients in skilled nursing facilities (SNFs) after the PHE. But CMS will allow more frequent subsequent SNF visits via telehealth, every 14 days instead of every 30 days.

Continued Coverage of Telehealth Physician Supervision of Residents and Services “Incident To” Physicians’ Services

CMS is continuing Medicare coverage of telehealth services delivered incident to the services of a billing professional until the later of the end of the year when the PHE ends or on Dec. 31, 2021. To bill Medicare, the supervising physician must be immediately available to intervene using live, two-way, audio-visual technology (e.g., a Zoom call with the patient, non-physician practitioner and physician).

In addition, CMS will continue to cover services for residents who are supervised by physicians via telehealth until the end of the PHE. Teaching physicians must use real-time audio-visual technology. This coverage will be extended after the PHE only in rural areas.
CMS clarified that Medicare will continue covering e-visits provided by licensed clinical social workers, clinical psychologists, (as well as physical therapists, occupational therapists, and speech-language pathologists) on a permanent basis. E-visits include brief online assessment and management services via telehealth as well as virtual check-ins and remote evaluation services.

CMS has created two new codes for this expanded coverage:

  • Brief communication technology-based service, e.g. virtual check-in, by a qualified healthcare professional who cannot report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous seven days nor leading to a service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion (G2251); and
  • Remote assessment of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related service provided within the previous seven days nor leading to a service or procedure within the next 24 hours or soonest available appointment (G2250).