**The Evolving Landscape of Telehealth: Key Takeaways for Healthcare Organizations and Professionals**
The healthcare landscape is undergoing a significant transformation, particularly in the realm of telehealth. With the release of the annual Proposed Rule by the Centers for Medicare & Medicaid Services (CMS) and the publication of the revised List of Telehealth Services for Calendar Year (CY) 2023, there are several key updates and clarifications that healthcare organizations and professionals need to be aware of. This article delves into the most pertinent changes and their implications for the industry.
1. CPT Code 99453, 99454, 99457, and 99458: Remote Physiologic Monitoring (RPM) and Remote Therapeutic Monitoring (RTM)**
The CMS Proposed Rule for CY 2024 has introduced several changes related to RPM and RTM services. These include:
- **Clarifications on Prerequisites**: The rule aims to clarify prerequisites for billing certain RPM and RTM codes. It emphasizes that RPM can only be furnished to an "established patient," a stipulation that was waived during the Public Health Emergency (PHE) but will be reinstated post-PHE.
Separate Payments**: The rule proposes that Medicare will pay separately for RPM and RTM during global surgery periods. This is a significant shift that will impact billing practices.
Inclusion in Primary Care Services**: RPM has been added to the definition of primary care services for the Medicare Shared Savings Program (MSSP) beneficiary assignment.
2. CPT Code 98976, 98977, 98978, 98980, and 98981: Data Collection Requirements**
The Proposed Rule has reinstated the requirement to collect data for at least 16 days of a 30-day period for certain RTM CPT codes. This move has been met with resistance from industry stakeholders who argue for more flexibility in this requirement.
3. CPT Code G0511: Reimbursement for RHCs and FQHCs**
Historically, Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) were not authorized to bill separately for RPM and RTM services. The Proposed Rule is now allowing these centers to bill for these services using the general care management code, HCPCS code G0511.
4. Digital Cognitive Behavioral Therapy (CBT)**
CMS is actively seeking information on the use of digital CBT in clinical practice. This move indicates a growing interest in the potential of digital therapies in enhancing patient care.
5. Telehealth Services for CY 2023**
The revised List of Telehealth Services for CY 2023 has clarified that all codes on the list are available through the end of CY 2023. This provides clarity for providers on the scope of telehealth coverage available.
6. Continuing Flexibilities Post-PHE**
Several telehealth flexibilities introduced during the PHE, such as the expanded definition of "originating site" and the use of audio-only platforms for certain E/M services, will continue through December 31, 2024.
7. Licensure Restrictions**
Post-PHE, licensure restrictions will revert to a deferral to state law, meaning providers will need to ensure they are compliant with state-specific regulations.
**Conclusion**
The evolving telehealth landscape presents both opportunities and challenges for healthcare organizations and professionals. Staying informed and adapting to these changes is crucial for ensuring optimal patient care and compliance with regulatory standards. Healthcare stakeholders are encouraged to provide feedback on the Proposed Rule by September 11, 2023, to influence the future direction of telehealth policies.
**Sources**:
- [CMS Proposed Rule for CY 2024](https://www.regulations.gov/)
- [Revised List of Telehealth Services for CY 2023](https://www.sheppardhealthlaw.com/articles/key-healthcare-provisions-of-the-consolidated-appropriations-act-2023/)
- [AMA Telehealth Policy, Coding & Payment](https://www.ama-assn.org/practice-management/digital/ama-telehealth-policy-coding-payment)