Insurance Coverage of Telehealth After the COVID-19 Pandemic
The COVID-19 pandemic changed the fabric of many industries, particularly mental and behavioral health providers and insurance companies. If you will recall, early in the pandemic insurance companies and government payers quickly adapted their policies and payment structures to accommodate the mental and behavioral health industry including waiving deductibles and cost share. As we move farther away from the pandemic the rules to telehealth will change once more. This blog will help keep you up to date on what the permanent changes are to telehealth coverage, what the government and private insurers are phasing out, and additional considerations for telehealth coverage in a post-pandemic world.
Permanent Changes to Telehealth Coverage
According to telehealth.hhs.gov, there are two significant changes to the telehealth coverage guidelines from a government payer perspective, outlined in their article Telehealth policy changes after the Covid-19 public health emergency. The first change listed in the article is that “Medicare patients can now receive telehealth services, including audio-only services, for mental/behavioral health care in their homes in any part of the country if certain conditions are met.” This is a significant permanent change in the coverage policy for Medicare and Medicaid. Before COVID-19 this was not a covered service. The question that providers, and Practice Solutions, is wondering is how this will apply to the private insurance industry.
So far, there has not been a lot of guidance from the private health insurance industry, but we expect that as government payers integrate telehealth coverage the private health insurance companies will follow suit in order to stay competitive with other subscribers. Bear in mind that if you are in-network with any of the MAC companies throughout the country, they must follow the Medicare guidelines for mental and behavioral health coverage. This is good news to anyone with a large Medicare caseload.
The second major permanent change to the telehealth coverage guidelines according to the telehealth.hhs.gov article linked above is that “the CY 2022 Telehealth Update Medicare Physician Fee Schedule (PDF) has already codified the continued coverage of video-based mental health visits for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) on a permanent basis. For more information, refer to the Final CY 2022 Medicare Physician Fee Schedule Fact Sheet (PDF) from the National Telehealth Policy Resource Center.” Basically, what this means is that if your practice is listed as a Federally Qualified Health Center or a Rural Health Clinic you will be able to bill and be paid for video-based mental health visits indefinitely. Many private practices can change their taxonomy code, but we recommend consulting with a healthcare attorney before making that kind of a decision.
However, if you are already listed as one of those two entities you can celebrate knowing that indefinitely telehealth services are going to be available as a reimbursable service.
Phased Out Changes to Telehealth Coverage
While there are promising permanent changes to the telehealth coverage policies there are some changes that are going to be phased out. For some context, congress passed the Consolidated Appropriations Act, 2022 which states that at the end of the COVID-19 Public health emergency, a 151 day waiting period begins after which there are several changes to telehealth coverage that will end. As listed in the HHS Article mentioned previously, the changes that are going to end are:
“Increased flexibility regarding where the patient receives Medicare telehealth services, as well as where the services originate will revert back to match the restrictions that were in place prior to the COVID-19 public health emergency.
Medicare reimbursement for mental health telehealth services will again require an in-person visit within 6 months of initial assessment and every 12 months following.
Medicare reimbursement for telehealth visits furnished by physical therapists, occupational therapists, speech language pathologists, and audiologists will no longer be allowed.
Medicare will no longer cover audio-only visits for physical health encounters.
FQHCs and RHCs will no longer be able to be reimbursed as distant site telehealth providers for non-mental health services.”
The main point from these changes that will impact your claims and payment is ensuring which place of service is listed on your claims. During the pandemic there was a lot of clarification needed from the insurance companies about which place of service code to use. We will need to gain clarity at the end of the 151 day waiting period.
The other change that is going to impact providers during this time is the stipulation that says you will need an in-person visit periodically through the treatment cycle. This is something that you will need to work into your treatment with patients if you would like payment to continue being furnished for your services.
Additional Considerations for Telehealth Coverage Post-COVID-19
Changes to the payer policies for telehealth and special regulations that were implemented during the pandemic are inevitable. Here are some thoughts that we have for you to keep your billing program running smoothly throughout another time of transition in your private practice.
Be flexible. We know changes are hard and impact the payment to your practice, but we encourage you to be as flexible as possible as you experience changes from a policy level.
Be informed. If you are learning as you go, we recommend that you subscribe to every newsletter and informational bulletin for each payer that you are in-network with. They will do their best to keep you informed as to their changes and leanings during this time. If you are outsourcing your billing then we recommend touching base with your biller or watching the company’s blog for any relevant updates or information.
Be communicative with your patients. Patients and clients are the ones that will bear most of the stress during these times of transition. They will need all of our support and we ought to do our best to set their expectations appropriately and make sure they understand how these changes can impact their lives.
We know that the COVID-era has ignited hard and difficult feelings and situations in the mental health industry for providers and patients alike. We know that we have experienced several significant pivots in policy and payment through this time. Practice Solutions exists to remove the burden of billing and to educate you on best practices when managing the revenue cycle in your practice. We want to encourage you to be calm and collected through this time of transition and know that we are here to help. We are happy to answer any questions or concerns you have about billing. Feel free to subscribe to the blog for weekly updates and free educational content.