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March 30, 2020 - Updated: 04.01.20

Telehealth Services During the Public Health Emergency

The Centers for Medicare & Medicaid Services (CMS) has broadened access to Medicare telehealth services so that beneficiaries can receive a wider range of services without having to travel to a healthcare facility. The policy changes build on the regulatory flexibilities granted under the President’s emergency declaration and actions to prevent the spread of community COVID-19.

Key points on the waiver effective for dates of service March 6, 2020, through the duration of the COVID-19 Public Health Emergency (PHE):

  • Medicare can pay for office, hospital, and other visits furnished via telehealth across the country
  • These visits are considered the same as in-person visits and are paid at the same rate as regular, in-person visits.
  • Medical necessity and documentation requirements still apply to all services.
  • Unlike other claims for which Medicare payment is based on a “formal waiver,” telehealth claims don’t require the “DR” condition code or HCPCS modifier CR.  Modifiers are required for:
    • HCPCS modifier GT:  When a telehealth service is billed under CAH Method II.
    • HCPCS modifier G0:  When telehealth service is furnished for purposes of diagnosis and treatment of an acute stroke.
    • HCPCS modifier GQ:  When a telehealth service is furnished via asynchronous (store and forward) technology as part of a federal telemedicine demonstration project in Alaska and Hawaii.
  • HCPCS code Q3014 is still billed for the originating site facility fee, but without the geographic location restrictions.
  • A range of providers (subject to state law), including doctors, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, clinical social workers, registered dietitians, and nutrition professionals, will be able to offer telehealth to their patients.
  • The provider must use an interactive audio and video telecommunications system that permits real-time communication between the distant site and the patient at home.  This includes Facetime and Skype.
  • The HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing (deductible/co-insurance) for telehealth visits paid by federal healthcare programs.
  • HHS will not conduct audits to ensure that a prior relationship (i.e., established patients) existed for telehealth claims submitted during this public health emergency.

CMS announced in the Fact Sheet released on March 30, 2020, Additional Background: Sweeping Regulatory Changes to Help U.S. Healthcare System Address COVID-19 Patient SurgeExternal Website that CMS will now pay for more than 80 additional services when furnished via telehealth. Services furnished via telehealth may include:

  • Emergency department visits
  • Initial nursing facility and discharge visits
  • Home visits
  • Face-to-face visits requirements for clinicians for patients in inpatient rehabilitation facilities, hospice and home health
  • Hospice services to patients receiving routine home care, if it is feasible and appropriate to do so.

For a complete list of the Telehealth ServicesExternal Website, refer to the Covered Telehealth Services for PHE for the COVID-19 pandemic, effective March 1, 2020Zip File.


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