On May 11, 2023, the Public Health Emergency (PHE) will come to an end. With this end the big question becomes how this will affect my group or practice. Here is the Neolytix list of key points you should be aware of.
There are two categories that can affect many healthcare providers. They are telehealth and laboratory services. Many of the services in these categories are affected with permanent or temporary changes by Medicare. Some temporary changes end on either May 11, 2023, or December 31, 2024.
When the PHE began individuals with Medicare had broad access to telehealth services, in their homes, without the geographic or location limitations. “Telehealth” includes services provided through telecommunications systems (for example, computers and phones) and allows health care providers to give care to patients remotely in place of an in-person office visit.
- Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) can serve as a distant site provider for behavioral/mental telehealth services.
- Medicare patients can receive telehealth services for behavioral/mental health care in their home. Performed by audio/visual and audio only telehealth services.
- There are no geographic restrictions for originating site for behavioral/mental telehealth services.
- Rural hospital emergency department are accepted as an originating site.
Temporary Changes until December 31, 2024
- Federally Qualified Health Center (FQHC)/Rural Health Clinic (RHC) can serve as a distant site provider for non-behavioral/mental telehealth services.
- Medicare patients can receive telehealth services authorized in the Calendar Year 2023 Medicare Physician Fee Schedule in their home.
- There are no geographic restrictions for originating site for non-behavioral/mental telehealth services.
- Some non-behavioral/mental telehealth services can be delivered using audio-only communication platforms.
- An in-person visit within six months of an initial behavioral/mental telehealth service, and annually thereafter, is not required.
- Telehealth services can be provided by a physical therapist, occupational therapist, speech language pathologist, or audiologist.
What clinicians need to know after December 31, 2024, when the extension of federal flexibilities ends.
- Medicare will no longer reimburse audiologists for any telehealth services. You can enter into private pay arrangements with Medicare beneficiaries to continue providing telehealth services, if the patient agrees. HIPAA flexibilities, which applied to Medicare telehealth services, will also expire at the end of the federal PHE.
- Medicare will no longer reimburse speech language pathologists directly for any telehealth services. The HIPAA flexibilities, which applied to Medicare telehealth services, will expire May 11, 2023, the end of the federal PHE.
- New modifier 93 represents audio only services currently required in 2023.
- The 2023 Physician Fee Schedule instructed practitioners to continue to use the POS that would have been used if the patient was seen in person.
- Do not use POS 02 or 10 if you have used POS 11 for the office service. The use of POS 02 or 10 for Medicare patients will result in lower reimbursement in 2023.
These temporary changes include:
- HCPCS codes G2023 specimen collection and G2024 specimen collection from nursing home patients for specimen collection. Will no longer be payable.
- HCPCS codes U0003, U0004, and U0005 are used for an additional payment when performing high-throughput testing. Will no longer be payable.
- Medicare will require all COVID-19 and related testing that is performed by a laboratory to be ordered by a physician or non-physician practitioner.
- Commercial health plans will no longer be required to reimburse out-of-network labs for COVID-19 tests based on their listed cash charge.
- Published price transparency for Covid testing.
Additional temporary changes
- Coverage for antibody COVID tests will be covered under the individual discretion of each Medicare Administrative Contractor (MAC).
- A number of blanket waivers for physician self-referral laws (Stark Law) were waived early during the PHE to allow for limited remuneration and self-referrals for services strictly related to COVID testing. Once the PHE ends, labs and physicians must again comply with all provisions under Stark Law.
As you can see, the end of the Public Health Emergency is fast approaching. Here at Neolytix, we are available to assist your implementation of any changes that will affect your group or practice following the end of the PHE.
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