On July 13, 2023, the Facilities for Medicare & Medicaid Providers (CMS) issued a proposed rule that asserts and solicits public feedback on proposed coverage adjustments for Medicare funds underneath the Calendar 12 months (CY) 2024 Doctor Payment Schedule (PFS) and different Medicare Half B points, efficient on or after January 1, 2024.
The calendar yr (CY) 2024 PFS proposed rule is considered one of a number of proposed guidelines that replicate a broader Administration-wide technique to create a extra equitable well being care system that leads to higher entry to care, high quality, affordability, and innovation.
The proposed modifications embrace a number of pertaining to telehealth coverage within the Medicare program for 2024. One of many main takeaways from the proposed 2024 PFS is the clarification that sure telehealth flexibilities that had been beforehand prolonged till 151 days after the top of the general public well being emergency (PHE) have now been prolonged till December 31, 2024, in accordance with amendments made by the Consolidated Appropriations Act, 2023. These extensions have been recognized because the CAA’s passage in December final yr and has additionally been addressed in a sequence of truth sheets and FAQ paperwork.
Nevertheless, there have been additionally some new adjustments addressed within the 2024 PFS. For instance, yearly CMS will take into account including new providers to their record of codes which might be reimbursable by way of telehealth. Whereas they didn’t determine so as to add any new codes on a everlasting foundation to the record (although many stay on the record briefly by means of the top of 2024), they did suggest so as to add various codes to Class 3 (CMS’ present non permanent record), together with sure codes for well being and well-being teaching providers. Moreover, CMS introduced a proposed revision to their telehealth code classification course of, shifting from a Class 1, 2 and three classification system to a binary ‘everlasting’ or ‘provisional’ classification in an try and simplify the method starting in CY 2025. To be able to make the steps for getting a code accepted for inclusion in both the everlasting or provisional telehealth lists clear, CMS proposes a five-step course of that’s detailed within the proposed 2024 PFS, which incorporates consideration of the proof of medical advantages.
A couple of extra adjustments proposed within the doc are listed under:
The record of telehealth practitioners is amended to acknowledge marriage and household therapists and psychological well being counselors as telehealth practitioners, efficient Jan. 1, 2024.
CMS pays for place of service (POS) 10 on the non-facility PFS fee, whereas 02 might be paid on the facility fee starting Jan. 1, 2024.
Frequency limitation can be eliminated for subsequent inpatient visits by means of the period of CY 2024.
A number of clarifications are supplied for billing each distant physiologic monitoring (RPM) and distant remedy monitoring (RTM) codes.
Direct supervision is allowed to incorporate real-time audio video interactive telecommunication by means of Dec. 31, 2024 (together with for FQHCs and RHCs). Direct supervision necessities are additionally addressed for occupational therapists in personal apply (OTPP) and bodily therapists in personal apply (PTPP) for unenrolled bodily and occupational therapists when offering distant RTM.
CMS might be accepting feedback on their proposals till 5:00 pm EST on September 11, 2023, and RCPA will evaluation the doc and work with the Nationwide Council for Psychological Wellbeing in drafting suggestions. We welcome supplier suggestions and feedback to be included and ask that you simply contact and share these along with your RCPA Coverage Director.
