In a major escalation of its already expansive COVID-19 Public Health Emergency (PHE) regulatory waivers, CMS will now allow any clinical practitioner to provide telehealth services to Medicare beneficiaries, one of the biggest changes announced in an April 30 policy release.

The new rules explicitly allow physical therapists, occupational therapists, and speech pathologists to furnish and bill for telehealth services. CMS will also allow more E/M codes to billed as telehealth services using only a phone, without real-time video. Other provisions will allow patients to get a COVID-19 test without the need for a physician order, hospitals to be paid for services rendered in temporary locations like parking lot tents, and more.

A bullet list of highlights from the full CMS document is below:

Telehealth changes

• Limitations on practitioner type are waived. For the duration of the COVID-19 PHE, CMS will waive restrictions on which provider type can bill for telehealth services. Now, other practitioners besides physicians, nurse practitioners, and physician assistants can bill for telehealth. This includes physical therapists, occupational therapists, and speech language pathologists.
• Audio-only telehealth list is expanded. CMS will allow a variety of therapy-related E/M codes to be billed as telehealth services with an audio-only connection, i.e. over the phone, without requiring real-time video. This includes psychotherapy services, medical nutrition counseling, diabetes self-management training, tobacco use cessation counseling, and more. The full list can be found on the CMS telehealth-eligible code list, which was just updated again on April 30.
• Payments increased for audio-only services. In addition to allowing many behavioral health and patient education and counseling services to be billed using only audio communication, CMS is bumping up the payment for these services from the current range of $14-$41 to a range of $46-$110, bringing them in line with payments for similar office/outpatient visits. This payment change will be retroactive back to March 1, 2020.
• Hospitals may bill as the originating site for telehealth, even when the patient is located at home. This will be allowed for telehealth services furnished by hospital-based practitioners to Medicare patients who are registered as hospital outpatients.

COVID-19 testing changes

• Physician order no longer required for testing. Medicare patients no longer need a written practitioner’s order to receive a COVID-19 test or certain laboratory tests required to diagnose COVID-19.
• Pharmacists can collect specimens and bill Medicare. Pharmacists can work with a physician or other practitioner credentialed to bill Medicare to provide assessment and specimen collection services relating to COVID-19 diagnosis, and the physician or other practitioner can bill Medicare. Pharmacists may now perform COVID-19 tests if they are currently enrolled with Medicare as a laboratory, provided this is allowed under their state scope-of-practice laws. This allows Medicare patients to be tests at parking lot test sites that are often operated by pharmacies.
• CMS will now cover serology tests. To help determine whether a patient has developed an immune response to COVID-19 and may therefore no longer be at immediate risk of infection, CMS will cover serology tests that look for antibodies to the virus. This includes processing patient-collected samples from home as part of FDA-authorized COVID-19 serology tests.

Workforce changes

• Non-physician practitioners may provide home health services. In keeping with provisions in the Coronavirus Aid, Relief, and Economic Security (CARES) Act, nurse practitioners, clinical nurse specialists, and physician assistants may now provide home health services. This means these providers may order home health services, create and review plans of care for home health patients, and both certify and re-certify homebound status to determine whether patients continue to be eligible for home health services.
• PT/OT assistants can perform outpatient maintenance therapy. CMS will allow physical and occupational therapists to delegate maintenance therapy services to physical and occupational therapy assistants working in outpatient settings. The move is intended to free up PT/OT providers so they can perform other services and improve patient access to care.

Hospital changes

• Services performed in temporary expansion locations will be paid for. Outpatient hospital services including provider-administered drugs, behavioral health services, and wound care that are delivered in temporary expansion locations will be paid. Such locations could be parking lot tents, converted hotels, or even patients’ homes if they are temporarily designated as part of a hospital.
• OPPS payments will apply to off-campus locations. CMS will allow provider-based hospital outpatient departments that relocate off the hospital campus to apply for a temporary exception in order to continue receiving payment under the Outpatient Prospective Payment System (OPPS) rather than under the Medicare Physician Fee Schedule. Hospitals may relocate outpatient departments to more than one off-campus location or partially re-locate off-campus while continuing to deliver care at the original on-campus sites.

Sean’s takeaways

While we are still in the middle of this pandemic and continue to hope that those heavily impacted areas will soon see their curves bend downward, we are excited to see this administration listening to front line healthcare providers. By further reducing barriers to telehealth and easing other regulatory restrictions, CMS is getting more care to those in need. We anticipate further changes being issued in the coming days and weeks. For now this is a very encouraging sign for all of us in the healthcare industry.

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