Published July 11th, 2024
Every year, the Centers for Medicare & Medicaid Services (CMS) issues a proposed set of changes to payment and other coverage and reporting requirements for providers offering care to Medicare beneficiaries.
Multi-step Process for Updating Payment Policy on Physician Fee Schedule and Payment Method for Federally Qualified Health Centers and Rural Health Clinics¹
This is the process and timeline for clinicians paid under the Medicare Physician Fee Schedule, as well as the separate payment systems that apply to Federally Qualified Health Centers and Rural Health Clinics.
- PROPOSED RULE | CMS issues a proposed rule with proposals related to payment
- COMMENT PERIOD | Stakeholders typically have 60 days to comment
- FINAL RULE | CMS then reviews the comments and issues a final rule no later than December 31st
- EFFECTIVE DATE | The effective date of the changes is January 1st
*There is a parallel process for hospitals and other facilities/providers, but with different timelines.
[1] From MedPAC accessed on July 11, 2024: Federally qualified health centers (FQHCs) and rural health clinics (RHCs) furnish services typically provided in outpatient clinic settings. While most clinician services furnished to Medicare beneficiaries are billed under the fee schedule for physicians and other health professionals, the Congress established special payment rules for FQHCs and RHCs to improve access to primary care services in rural and underserved areas. FQHC and RHC services are medically necessary medical visits, mental health visits, or qualified preventive health visits. For most services, the visit must be a face-to-face (one-on-one) encounter between the patient and an eligible clinician. However, beginning in 2022, mental health visits using interactive, real-time telecommunications technology are considered FQHC and RHC services.
Proposed Changes to Telehealth Coverage
For those clinicians receiving payment on the Medicare physician fee schedule and those paid under the payment systems for federally qualified health centers and rural health clinics, the Agency made significant proposals.
- FQHCS / RHCS.
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- CMS proposes to allow payment, on a temporary basis, for non-behavioral health visits furnished via telecommunication technology. Under the proposal, RHCs and FQHCs would continue to bill for RHC and FQHC services furnished using telecommunication technology services by reporting HCPCS code G2025 on the claim, including services furnished using audio-only communications technology through December 31, 2025.
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- CMS proposes to continue to allow direct supervision via interactive audio and video telecommunications and to extend the definition of “immediate availability” as including real-time audio and visual interactive telecommunications (excluding audio-only) through December 31, 2025.
- CLINICIANS BILLING ON PFS. Congress’ temporary extension of flexibilities related to payment for many telehealth services is scheduled, by statute, to expire at the end of 2024. As a result, CMS has indicated that it will not extend flexibility for providers who do not meet the Pre-COVID-19 PHE requirements which include provisions related to rurality.
- PERMANENT EXTENSION FOR AUDIO-ONLY. CMS proposes to permanently allow two-way, real-time audio-only communication technology for any telehealth service furnished to a beneficiary in their home if the distant site physician or practitioner is technically capable of using an interactive telecommunications system but the patient is not capable of, or does not consent to, the use of video technology.
- PROVIDER LOCATION REPORTING. CMS proposes to allow through 2026 a distant site practitioner to use their currently enrolled practice location instead of their home address when providing telehealth services from their home.
- VIRTUAL DIRECT SUPERVISION. CMS proposes a new authority for virtual direct supervision of incident to services. CMS also proposes to continue broader existing virtual direct supervision authority through 2025. This includes the current policy allowing teaching physicians to have a virtual presence for purposes of billing for services furnished involving residents in teaching settings who are offering a virtual service.
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