In This Public Health Emergency Update:
- Public Health Emergency Extension
- Telehealth Recommendation
- Telehealth Audits
- General Update
Public Health Emergency (PHE) Extension
Recently, the Department of Health and Human Services (HHS) extended the PHE again. The renewal officially took place on April 16, 2022, and it will run though July 15, 2022. There have been some indications from the current administration that the PHE may continue through the end of 2022, but extensions can only be applied in 90-day increments.
Fortunately, these relatively brief renewal periods do not need to mean uncertainty for providers relying heavily on telehealth. Due to the Consolidated Appropriations Act of 2022 that passed mid-march, all HHS/CMS waivers will continue to be in place for the duration of the PHE, and then for an additional 151 days or approximately five months.
Telehealth Recommendation
As stated above, all COVID-associated telehealth waivers will continue for five months after the official end of the PHE. Despite this, there are reasons why telehealth may not be the best long-term solution for all providers. Telehealth reimbursement tends to vary depending on location, practice, service, and payor. The most notable variable is commercial versus Medicare coverage.
With commercial payors, it is important to determine ahead of a patient’s appointment whether or not they are eligible for telehealth. If they are eligible, reimbursement rates are markedly lower than in-person care. However, Medicare continues to offer more opportunity with telehealth, currently paying for audio/visual at the same rate as in-person visits and even raising audio-only reimbursement rates in the 2022 Physician fee schedule. Audio-only is still significantly lower than the in-person rates.
With these changes and allowances, it is the recommendation of EMB to not rely wholly on telehealth but to integrate it into your services as an option for your patients, if you choose to utilize it.
Telehealth Audits
In 2022, there are many ongoing telehealth-specific audits, in particular from the Office of Inspector General. Every practitioner who has offered telehealth services during the PHE should anticipate this analysis of your records as a likely potential. As always, it is important to maintain best practice for telehealth by keeping a thorough record of all aspects of the visits, including duration. Patients must also be fully informed of all cost-sharing, and eligibility should be determined ahead of time.
General Update
EMB has been reviewing our current partnerships with collection agencies to determine whether or not we have the best fit for our providers who utilize this service. Please keep an eye out for communication from Diana about exploring your options, if you might be interested.