In March of this year, you’ll recall that Centers for Medicare and Medicaid Services (CMS) let out the reins on telehealth services, resulting in telemedicine experiencing as much growth in three weeks as it had in the previous several years. Later, services were expanded even further to include things like physical therapy, occupational therapy, and many inpatient services.

The new proposed changes

Earlier this month, CMS released its proposed physician fee schedule for 2021, and they’ve predictably scaled back the services that are covered via telehealth. Gone are 74 codes that CMS finds have “no likelihood of clinical benefit” after the COVID-19 public health emergency ends. Some of the codes that are going away are for certain psychological testing, physical and occupational therapy, and several inpatient management codes.

In their place, though, CMS has approved nine new codes, covered through 2021 at least and ranging from care planning for patients with cognitive impairment to group psychotherapy. The mental health orientation of these new codes is exciting to us at KBGH because of our ongoing work with the Path Forward for Mental Health and Substance Abuse initiative, which includes improved access to tele-behavioral health as one of its five core areas of improvement. COVID-19 has brought an increased focus on the need for tele-behavioral health. Research released from the Wellbeing Trust reports that there could be an increase in “deaths of despair” with 75,000 more deaths due to suicide and drug misuse due to the pandemic. While more people are seeking mental health care, tele-mental health could make access easier, and also help overcome stigma still associated with mental health issues. We want to see telehealth used more extensively in mental health services! If you are interested in working with KBGH on this, please contact us.

But what’s the bottom line for the future of telehealth? It’s pretty positive overall. If your employee population is relatively healthy and unlikely to be hospitalized, and if you are located in a place with plenty of hospital beds staffed with ample physicians, then these new CMS rules aren’t likely to affect you much at all. For sicker patients, or for patients who may only have a hospital readily available that doesn’t have easy access to specialist physicians, these new rules may change their care compared to the last five months. But on the bright side, I hope that the several new telehealth services that are covered on a temporary basis are a signal that CMS has some willingness for experimentation moving forward.

Providing your feedback

If you’re interested in giving CMS feedback on these changes, please consider sending comments on the proposed rule at this link or by mail at:

Centers for Medicare & Medicaid Services, Department of Health and Human Services

Attention: CMS-1734-P

P.O. Box 8016, Baltimore, MD 21244-8016.

Comments on the proposed rule must be received by 5:00 p.m. on October 5, 2020.

As the Medical Director of the Kansas Business Group on Health I’m sometimes asked to weigh in on topics that might affect employers or employees. This was a reprint of a blog post from KBGH.