Resources & Reports

Last month, the Department of Health and Human Services (HHS) Office of the Inspector General (OIG) released a new audit report related to telehealth evaluation and management (E/M) services. The nationwide audit of services provided between March 1, 2020 through November 30, 2020 found that, generally, providers met Medicare requirements when billing for evaluation and management (E/M) services (office/outpatient visit codes) via telehealth. While some documentation issues were identified on a small amount of the claims sampled (5 out of 110), the OIG report did not include recommendations given the high overall level of provider compliance found.

While some very important questions regarding the future of temporary waivers on telehealth policies in Medicare, as well as the prescribing of controlled substances, continue to be unanswered, there have been some new developments in the past few weeks related to federal telehealth policy. Some of the recent discussions in Congress as well as actions by the Biden Administration may provide some insight on the fate of some of these temporary telehealth policies.

CCHP’s March Newsletter is here! This month’s topics include – Telehealth Toolkit Update: Navigating Policies and Best Practices for Medicaid and CHIP Services; Telehealth Advocates Alert DEA to Prescription Challenges for Controlled Substances; CMS Memo Addresses Texting Patient Orders and Compliance Concerns for Hospitals and CAHs; Senate Hearing on AI Discusses Striking a Balance between Regulation vs. Innovation; IN CASE YOU MISSED IT:  Updated CMS Telehealth Factsheet & Noridian Addresses Telehealth Claims Issue with POS 10; Latest Policy Developments in CCHP’s Telehealth Policy Finder and Policy Trends Map; Unlocking the Potential of Remote Patient Monitoring in Cancer Care; IN CASE YOU MISSED IT:  Dive into Telehealth Policy with CCHP Executive Director, Mei Kwong!

Last month the Centers for Medicare and Medicaid Services (CMS) released an updated Telehealth Services Medicare Learning Network (MLN) Fact Sheet reflecting new information for 2024. Most of the guidance remains unchanged and updates largely focus around incorporating already adopted policies from the Consolidated Appropriations Act, 2023 (CAA 2023) and CY 2024 Physician Fee Schedule (PFS) Final Rule. However, the document serves to assist providers struggling to keep up with shifting billing rules and offers the potential to clarify outstanding reimbursement issues as well as provide a reminder of current Medicare telehealth policies.

Prior to the COVID-19 pandemic, telehealth research frequently focused on its use to access mental and behavioral health services, since the services were the most commonly considered as appropriate to receive virtually rather than in-person. As attention to and demand for telemental health access increased during the pandemic, additional studies have been released showing both trends and areas for future research as well as creating new policy. For instance, determining how many mental health clinicians have shifted their practices post-pandemic to primarily virtual, and how that trend interplays with federal and state policies requiring in-person visits. Additionally, with a shortage of mental health providers in many areas of the country, telehealth is a key tool to increase access to needed health care providers. However, a variety of other policy issues such as lack of payer reimbursement and digital equity continue to be challenges and limit telehealth’s ability to fully address access.