Navigating Telehealth in 2024

Author: Keisha Wilson CCS, CPC, CPCO, CRC, CPB, CPMA, AAPC Approved Instructor

Our article last year, “Navigating Telehealth in 2024: A Comprehensive Guide”, covered the latest developments and requirements surrounding telehealth services under CMS and the end of the PHE, May 11, 2023. Almost a year later, so much has changed; some things remained the same or were extended. The healthcare landscape has rapidly transformed with the widespread adoption of telehealth services, especially in light of the COVID-19 pandemic. As we move into 2024, understanding the latest telehealth updates and regulations is crucial for healthcare providers, clinicians, administrative staff, coders, billers, and, most importantly, our patient population.

The article provides compliance tips for navigating telehealth effectively, which complements the discussion on compliance and regulatory considerations in the previous article. It will also outline the definition of telehealth services and their significance in modern healthcare, aligning with the discussion on telehealth and its benefits in the previous article; discuss the regulatory changes introduced in response to the COVID-19 pandemic, including extending telehealth flexibilities through December 31, 2024, echoing the extension of telehealth flexibilities mentioned in the previous article. Touching upon the technology requirements for telehealth services and the allowance of audio-only telehealth until the end of 2024, mirroring the discussion on telehealth requirements and technology

Overview of Telehealth Services

Telehealth, the remote delivery of healthcare services using digital communication technologies, has become indispensable for patient care, particularly in underserved areas or during public health emergencies. Under Medicare Part B, specific services provided via telehealth are reimbursed, allowing patients to access care from their homes or other locations conveniently.

Recent Updates and Regulatory Changes

In response to the COVID-19 pandemic, regulatory flexibilities were introduced to expand access to telehealth services. The Consolidated Appropriations Act of 2023 extended many of these flexibilities through December 31, 2024, with some provisions made permanent. Key updates include the expansion of originating sites and the inclusion of additional healthcare professionals as distant site practitioners for telehealth services, as well as the following:

  • Medicare beneficiaries now have expanded access to telehealth services across the United States, not just in rural areas.
  • Some non-behavioral or mental telehealth services may still have specific originating site requirements and geographic location restrictions.
  • Until December 31, 2024, all providers eligible to bill Medicare for professional services can offer distant-site telehealth.
  • Medicare allows telehealth visits from patients’ homes, eliminating the need for travel to healthcare facilities.
  • Certain telehealth visits can be conducted using audio-only technology for patients unable to use audio and video platforms.
  • The list of eligible providers for telehealth services has been expanded to include a broader range of healthcare professionals.
  • Medicare payment for telephone evaluation and management visits will continue at the same rate as office/outpatient visits until 2024. With the permanent removal of 99441-99443 as of January 1, 2025.
  • Starting in CY 2024, telehealth services provided to people in their homes will be paid at the non-facility PFS rate.
  • Modifier ’95’ should be used for certain telehealth visits, such as outpatient therapy services provided via telehealth.
  • Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) can provide telehealth services to Medicare beneficiaries.
  • Behavioral/mental telehealth services can now be delivered using audio-only communication platforms.
  • The requirement for an in-person visit within six months of a mental health service provided via telehealth has been delayed.
  • Medicare Physician Supervision Requirements have been temporarily modified to include “virtual presence” until December 31, 2024.
  • Coverage parity and payment parity requirements aim to ensure fair reimbursement for telehealth services.
  • Telemedicine flexibilities regarding the prescription of controlled medications have been extended, and I updated my SAMSHA in February 2024.
  • Medicare beneficiaries now have expanded access to telehealth services across the United States, not just in rural areas.
  • Some non-behavioral or mental telehealth services may still have specific originating site requirements and geographic location restrictions.
  • Until December 31, 2024, all providers eligible to bill Medicare for professional services can offer distant-site telehealth.
  • Medicare allows telehealth visits from patients’ homes, eliminating the need for travel to healthcare facilities.
  • Certain telehealth visits can be conducted using audio-only technology for patients unable to use audio and video platforms.
  • The list of eligible providers for telehealth services has been expanded to include a broader range of healthcare professionals.
  • Medicare payment for telephone evaluation and management visits will continue at the same rate as office/outpatient visits until 2024.
  • Starting in CY 2024, telehealth services provided to people in their homes will be paid at the non-facility PFS rate.
  • Modifier ’95’ should be used for certain telehealth visits, such as outpatient therapy services provided via telehealth.
  • Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) can provide telehealth services to Medicare beneficiaries.
  • Behavioral/mental telehealth services can now be delivered using audio-only communication platforms.
  • The requirement for an in-person visit within six months of a mental health service provided via telehealth has been delayed.
  • Medicare Physician Supervision Requirements have been temporarily modified to include “virtual presence” until December 31, 2024.
  • Coverage parity and payment parity requirements aim to ensure fair reimbursement for telehealth services.
  • Telemedicine flexibilities regarding the prescription of controlled medications have been extended.

Modifier Usage

POS 02: Telehealth Provided Other than in Patient’s Home. The location where health services and health-related services are provided or received through telecommunication technology. The patient is not located in their home when receiving health services or health-related services through telecommunication technology.

POS 10: Telehealth Provided in Patient’s Home. The location where health services and health-related services are provided or received through telecommunication technology. The patient is located in their home (a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health-related services through telecommunication technology.

Compliance Tips and Recommendations

Correct coding and billing practices are essential to ensure accurate reimbursement for telehealth encounters. When utilizing telehealth, services are deemed to be delivered at the patient’s physical location, necessitating typically that a provider holds licensure in the patient’s state. However, some states offer licenses or telehealth-specific exemptions enabling out-of-state providers to offer telemedicine services or allowing clinicians to deliver telehealth services in another state under specific conditions, such as agreeing not to establish an office there.

Staying compliant with telehealth regulations is paramount for healthcare providers. Here are some compliance tips to navigate telehealth effectively:

  • Ensure telehealth platforms comply with HIPAA regulations to safeguard patient privacy.
  • Familiarize yourself with updated CPT guidelines for audio-video and audio-only telehealth services.
  • Use appropriate modifiers and place of service codes when billing for telehealth encounters.
  • Obtain patient consent for telehealth services as required by Medicare guidelines.
  • Stay informed about regulatory changes and updates to telehealth policies to adapt your practice accordingly.

Looking Ahead: Post-PHE Telehealth Landscape

As we transition beyond the COVID-19 pandemic, telehealth remains critical to healthcare delivery. While many telehealth flexibilities have been extended, providers must prepare for future changes and policy updates. By staying proactive and informed, healthcare professionals can continue to leverage telehealth effectively to deliver high-quality care to patients across diverse settings.

In conclusion, navigating telehealth services under Medicare Part B in 2024 requires a comprehensive understanding of recent updates, regulatory requirements, and billing procedures. By adhering to compliance guidelines and staying abreast of evolving telehealth policies, healthcare providers can optimize telehealth services to meet their patients’ needs.

To schedule training for your organization or private practice providers or schedule a chart review, email us today at info@kwadvancedconsulting.com or visit the website and fill out the “contact us” form.

Resources for Telehealth Providers:

https://www.cms.gov/files/document/mln901705-telehealth-services.pdf

https://www.ama-assn.org/system/files/ama-telehealth-playbook.pdf

https://telehealth.hhs.gov/providers/billing-and-reimbursement/billing-and-coding-medicare-fee-for-service-claims?gad_source=1&gclid=CjwKCAjw48-vBhBbEiwAzqrZVHFn1q3mdsWCZDApO1TDv9p3F0hVv7UrOojbX0F6HJA8svt5E-23pRoCqXcQAvD_BwE

https://www.cchpca.org/all-telehealth-policies/

https://www.cms.gov/files/document/mm13452-medicare-physician-fee-schedule-final-rule-summary-cy-2024.pdf

https://www.cms.gov/files/document/telehealth-toolkit-providers.pdf

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