OPCA Telehealth Resources

Updated: July 10, 2020

As things rapidly develop regarding what we know about COVID-19, policies around telehealth have also been developing alongside of it. Below is a summary of what is covered by various public and private payers with the information that has been released. Keep in mind that events are evolving and to consider this a living document that could change frequently as new information and new policies become available/are enacted. CCHP will continue to make updates when they become available. It was announced on March 17 that the telehealth waiver in Medicare under HR 6074 has been implemented. Below is how the Medicare fee-for-service telehealth policies now stand.

Below is information regarding current policies and the changes made due to passage of HR 6074 and HR 748. HR 748 removed significant sections that HR 6074 had put into law.

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MEDICARE FEE FOR SERVICE TELEHEALTH COVERAGE
SUBJECT AREA CURRENT POLICY UNDER COVID-19
Location of the Patient Rural and site limitations are removed. Telehealth services can now be provided
regardless of where the enrollee is located geographically and type of site, which
allows the home to be an eligible originating site. Existing policies on facility fee
prior to COVID-19 changes apply.
Eligible Service All services that are currently eligible under the Medicare telehealth reimbursement
policies are included in this waiver. The list of eligible codes is available HERE.
Eligible Providers Changes in HR 748 added Federally Qualified Health Centers (FQHCs) and Rural
Health Clinics (RHCs) to the list of eligible providers for this emergency period
only. The addition of FQHCs and RHCs is not a permanent change to the eligible
provider list.
  • Physicians
  • Nurse practitioners
  • Physician assistants
  • Nurse-midwives
  • Clinical nurse specialists
  • Certified registered nurse anesthetists
  • Clinical psychologists (CP)
  • Clinical social workers (CSWs) (NOTE: CPs and CSWs cannot bill Medicare
    for psychiatric diagnostic interview examinations with medical services or
    medical evaluation and management services. They cannot bill or get paid
    for Current Procedural Terminology (CPT) codes 90792, 90833, 90836, and
    90838).
  • Registered dietitians or nutrition professional
  • FQHCs/RHCs (during the emergency period only)
Modality HR 748 removed the language HR 6074 put in regarding allowing phone to be
used as long as it had an audio/visual component. This change leaves only the
currently existing reference in law to “telecommunication systems” and
reference to store-and-forward for Hawaii and Alaska as the means of providing
telehealth delivered services. There is no definition given in law for
“telecommunication systems.” The requirement that it be an interactive audio
and visual system is in federal regulations. This would mean that CMS
theoretically would have flexibility in allowing phone to be a means of delivering
services. Until CMS issues more explicit guidance and information, the
assumption should be that it will still need to be interactive audio and visual. For
other types of eligible services not considered “telehealth” that still use
telehealth technologies, see “Other Technology-Enabled Services.”
Out-of-pocket costs/co-pays Still applies, but the OIG is providing health care providers flexibility to reduce or
waive fees.
Prior Existing Relationship to
Provide Care via Telehealth
The pre-existing relationship clause put in by HR 6074 was removed by HR 748.
Home Dialysis Patients During an emergency period, the Secretary has the power to waive the
requirements that home dialysis patients receiving services via telehealth must
have a monthly face-to-face, non-telehealth encounter in the first initial three
months of home dialysis and after the first initial three months, at least once
every three consecutive months.
Hospice During an emergency period, the Secretary may allow telehealth to meet the
requirement that a hospice physician or nurse practitioner must conduct a face-
to-face encounter to determine continued eligibility for hospice care.
Center for Connected Health Policy