Telehealth and the 2024 Physician Fee Schedule

Extended Telehealth Services and Locations

At the close of 2021, Congress passed the 2022 Consolidated Appropriations Act, extending specific telehealth provisions introduced during the COVID-19 Public Health Emergency (PHE) for an additional 151 days after the PHE concluded. Subsequently, in December 2022, the 2023 Consolidated Appropriations Act (2023 CAA) further prolonged these measures until the end of 2024. As Congress considers the possibility of making these telehealth policies permanent, industry stakeholders have eagerly awaited updates from the Centers for Medicare and Medicaid Services (CMS).

Following the conclusion of the PHE on May 11, 2023, CMS addressed some ongoing uncertainties and began refining its procedures in the first proposed Medicare Physician Fee Schedule (MPFS) since the PHE's termination.

The 2024 Proposed Medicare Physician Schedule extends certain telehealth flexibilities that were initiated during the pandemic. Notably, the restrictions on originating sites are still waived, permitting patients to receive telehealth services from any location, including their homes, broadening access to healthcare support, especially for those in rural or underserved areas.

Diverse Professional Engagement in Telehealth

The 2024 Proposed Medicare Physician Schedule proposes to implement certain rules enacted in the 2023 CAA, and will extend the inclusion of additional healthcare professionals in telehealth visits; occupational therapists, physical therapists, speech-language pathologists, and audiologists. These professionals can now offer their services remotely, which is expected to increase patient access to varied essential health services across the country, and is a major step forward in granting necessary medical care to rural locations and communities.

Revised Billing Codes

The introduction of new billing codes and the extension of continuation of some temporary codes through 2024 is pivotal in maintaining a smooth billing process. The proposed HCPCS code GXXX5 would primarily cover social health assessments and provide payment for the “Administration of a standardized, evidence-based Social Determinants of Health Risk Assessment tool, 5-15 minutes.” This proposed adjustment aims to streamline billing processes and ensure providers are fairly compensated for virtual services.

Simplified Administrative Processes

 Simplifying the telehealth process is crucial as it enhances accessibility for those in remote or underserved areas and improves efficiency, allowing healthcare providers to serve more patients effectively. It also promotes cost-effectiveness by reducing overhead costs and travel expenses and encourages wider adoption by making the system user-friendly, which is vital for continuous care, especially during public health emergencies. Additionally, a streamlined telehealth system better complies with regulations, ensures data security, and integrates seamlessly with other healthcare services, enhancing overall patient outcomes and supporting broader public health objectives. CMS is aiming to simplify the inclusion of services in the telehealth List, with the goal of reducing administrative burdens. This is in response to the growing need for telehealth services and CMS aims to make the process more flexible and responsive to healthcare advancements and practices.

Adjusted Reimbursement Rates

With the introduction of the national non-facility rate for services rendered at a patient’s home (Place of Service 10), reimbursements are set to become more equitable, bridging the gap between in-person and virtual care payments, providing reimbursement to providers at the same rate which would be paid if they provided the same service in-person at their designated office.  

These updates are pivotal as they reflect a shift towards a more integrated, accessible, and efficient healthcare system that leverages technology to meet diverse patient needs across the country. For healthcare providers and patients alike, understanding these changes is key to navigating the new landscape of telehealth services.