Medicare telehealth services in 2022

Q: Has Medicare's list of telehealth services changed for 2022?

Response: As the Center for Medicare and Medicaid Services (CMS) continues to evaluate the inclusion of telehealth services that were temporarily added to the Medicare telehealth list during the COVID-19 public health emergency, it has finally approved that certain services added to the Medicare telehealth list will remain on the list until December 31, 2023.

This will give CMS additional time to evaluate the need for continued inclusion of each service in the Medicare telehealth list of services.

CMS finally approved that it will extend through the end of 2023 the inclusion in the Medicare telehealth list of certain services temporarily added to the telehealth list that would otherwise be excluded after the end of the COVID-19 PHE or December 31, 2021. They also extended the inclusion of certain cardiac and intensive cardiac rehabilitation codes through the end of 2023. This will give CMS more time to gather data to decide whether each telehealth service will be permanently added to the Medicare telehealth list.

In addition, CMS introduces coding and payment for a longer virtual enrollment service on an ongoing basis.

Section 123 of the Consolidated Appropriations Act (CAA) removed geographic limitations and added the beneficiary's home as a permissible site of origin for telehealth services provided for the diagnosis, evaluation, or treatment of a mental disorder. Section 123 requires that there must be a face-to-face, non-body visit with a physician or practitioner within six months prior to the initial telehealth service, and a face-to-face, non-body visit must occur at least once every 12 months for these services.

Exceptions to the in-person visitation requirement may be made based on the beneficiary's circumstances (with the reason for this being indicated in the patient's medical record), and more frequent visits are allowed based on clinical needs on a case-by-case basis.

CMS has modified the current definition of an interactive telecommunications system for telemedicine services (which is defined as multimedia communication equipment that includes, at a minimum, audio and video equipment that allows two-way, real-time interactive communication between a patient and a physician or practitioner at a remote site) to include audio-only technology when used for telemedicine services for the diagnosis, evaluation or treatment of mental disorders provided by

CMS limits the use of an audio-only interactive telecommunications system to mental health services provided by physicians who have the ability to make two-way audio/video communications, but if the beneficiary is unable or does not consent to the use of two-way audio/video technology.

CMS also finalized the requirement for a new modifier for audio-only services, which will serve to verify that the provider had the ability to provide two-way audio/video communication but instead used audio-only due to beneficiary choice or limitations. They also clarify that mental health services may include services to treat substance use disorder (SUD).

The new modifier, Modifier 93 - Synchronized Telemedicine Service Provided via Telephone or Other Interactive Real-Time Audio-Telecommunication System, is effective January 1, 2022.

"Synchronous telehealth service" is defined as real-time interaction between a physician or other qualified health care professional (QHP) and a patient who is at a distance from the physician or other QHP. The body of information exchanged between the physician/QHP and the patient during a synchronous telehealth service must be of a scope and nature sufficient to meet the key components and/or requirements of the same service when provided in person.