As healthcare organizations expanded their telehealth services over the last few years, one pressing question arises – what happens when a public health emergency, such as the COVID-19 pandemic, ends? This uncertainty has been coined as the “telehealth cliff.”
To address this, the Centers for Medicare and Medicaid Services (CMS) took action through the Coronavirus Aid, Relief, and Economic Security Act. The organization granted flexibility for Medicare telehealth services by waiving certain requirements outlined in the Social Security Act’s section 1135.
This waiver specifically eliminates CMS’ geographic and originating site requirements for telehealth reimbursement under Medicare. Traditionally, telehealth services were only reimbursable if conducted at a physician’s office, skilled nursing facility, or hospital. Moreover, the patient had to be in a Health Professional Shortage Area or a country outside of any Metropolitan Statistical Area as defined by the U.S. Census Bureau.
The emergency declaration, initially in effect since January 31, 2020, has been extended every three months by the U.S. Department of Health and Human Services. However, the latest extension, set to expire May 11, 2023, will be the last.
Fortunately, health IT leaders and patients relying on telehealth received a lifeline. In December 2022, Congress passed the Consolidated Appropriations Act of 2023 – an omnibus appropriations bill that includes provisions impacting healthcare but also grants a two-year extension of Medicare telehealth waivers.
2023 Telehealth Reimbursement Updates
The newly passed Consolidated Appropriations Act of 2023 will impact healthcare organizations through the following changes:
Wider Originating Sites
Medicare will now reimburse telehealth services provided in any location, including patients’ homes or temporary residences. This change opens up more opportunities for healthcare organizations to reach patients wherever they may be.
Expanded Eligible Practitioners
With the new omnibus appropriations bill, occupational and physical therapists, speech-language pathologists, and audiologists are now qualified to provide telehealth services. This expansion of eligible practitioners ensures that patients have access to a wider range of specialized care.
Mental Health Services Update
The requirement for in-person mental health services has been delayed, allowing for greater flexibility in how these interventions are delivered. This change enhances access to mental health care for those who may not be able to attend in-person appointments.
Extended Acute Hospital Care at Home Program
The extension of the Acute Hospital Care at Home program benefits hospitals with expanded hospital-at-home services. In addition, it supports hospital-at-home companies, improving patient outcomes and reducing strain on traditional healthcare settings.
Extended Safe Harbor Exceptions
Telehealth services are now covered by high-deductible health plans. This change is largely due to the extension of safe harbor exceptions, ensuring that patients can take advantage of telehealth services without subjecting themselves to high out-of-pocket costs.
On May 3, 2023, the Drug Enforcement Administration (DEA) made an important announcement; they are extending waivers of the in-person rule mandated by the Ryan Haight Act of 2008. This bulletin means that patients can receive prescriptions of controlled substances through virtual appointments, further strengthening the significance of telehealth. This decision comes after the DEA received a record-breaking 38,000 comments on its proposed telehealth rules, highlighting the increasing demand for these services.
The Future of Telehealth Reimbursements
Telehealth reimbursement is entering a promising new era with exciting possibilities. Concerns surrounding the “telehealth cliff” have been addressed by decisive actions from CMS and Congress. The extension of Medicare telehealth waivers, detailed in the Consolidated Appropriations Act of 2023, also introduces significant changes that favor the virtual approach to patient care delivery.
However, securing permanent reimbursements for telehealth services beyond 2023 for Medicare beneficiaries requires ongoing advocacy and support from industry leaders and organizations. The work of the American Telemedicine Association (ATA) and similar entities will continue to be instrumental in shaping the future of telehealth reimbursements.
Collaborative efforts between policymakers, healthcare providers, and patient advocates are crucial in ensuring that telehealth remains a vital aspect of accessible and high-quality healthcare in this rapidly evolving field.