Telehealth policy updates
Federal legislation continues to expand and extend telehealth services for rural health, behavioral health, and telehealth access options, including from the home and audio-only for Medicare beneficiaries, beyond the COVID-19 Public Health Emergency.
Telehealth services for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) are extended until December 31, 2024 under the Consolidated Appropriations Act of 2023.
Rural Emergency Hospitals (REHs) were added as eligible Medicare originating sites for telehealth. This allows patients to be located at an REH when receiving telehealth services. The REH needs to meet the Health Resources and Services Administration’s (HRSA) “rural” classification to bill Medicare as an originating site under the Consolidated Appropriations Act of 2021.
The Consolidated Appropriations Act of 2023 builds on the Consolidated Appropriations Act of 2022 by continuing to delay in-person visit requirements before a patient may be eligible for telebehavioral health care services through December 31, 2024.
Under the Consolidated Appropriations Act of 2021, Medicare patients can receive telehealth services for behavioral health care in their homes in any part of the country. This includes most behavioral health services, such as counseling, psychotherapy, and psychiatric evaluations. The patient must have had at least one in-person visit with the provider in the six months before the telehealth visit in order to be eligible.
Extensions of telehealth access options
The Consolidated Appropriations Act of 2023 extended many of the telehealth flexibility waivers that were passed under Consolidated Appropriations Act of 2022, including geographic and originating site restrictions so that Medicare patients can continue to use telehealth services from their home and allowing audio-only telehealth services through December 31, 2024.
Additionally, the list of providers eligible to deliver telehealth services is expanded under the Consolidated Appropriations Act of 2023 so that Medicare beneficiaries can continue to receive physical therapy, occupational therapy, and speech language sessions via telehealth through to December 31, 2024.
First dollar coverage for telehealth services
The Consolidated Appropriations Act of 2023 allows patients with High Deductible Health Plans coupled with Health Savings Accounts to utilize first dollar coverage for telehealth services without first having to meet their minimum deductible.
Telehealth can be used to conduct recertification of eligibility for hospice care through to December 31, 2024 under the Consolidated Appropriations Act of 2023.
Acute hospital care at home
The Acute Hospital Care at Home Program has been extended to December 31, 2024 as part of the Consolidated Appropriations Act of 2023. This program heavily relies on telehealth services for hospitals to furnish inpatient services, including routine services, outside the hospital.