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Telehealth in 2024: Understanding the CMS Proposed Physician Fee Schedule and Its Impact

Updated: Sep 19, 2023



The Centers for Medicare & Medicaid Services (CMS) has released its proposed Physician Fee Schedule for 2024, prompting a significant level of interest and discussion in the healthcare community. While the changes encompass various aspects of healthcare, this blog focuses on what these proposed alterations mean for telehealth services. Additionally, it sheds light on the opinions of key stakeholders, like the American Telemedicine Association, about these proposed changes.


Key Telehealth Changes in the Proposed Rule


Geographic and Originating Site Flexibility


The proposed rule extends the flexibilities that have been in place during the COVID-19 pandemic. Specifically, the geographical restrictions have been waived, allowing patients to receive telehealth services regardless of their location. This is particularly helpful for rural and underprivileged communities.


Extended Coverage for Specific Providers


The rule aims to extend the ability to bill codes for remote patient monitoring to Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs). This opens up more opportunities for healthcare providers such as physical therapists, occupational therapists, speech therapists, and even audiologists to offer telehealth services. Marriage and family therapists and mental health counselors are also newly included as eligible providers.


Payment Parity and Rates


CMS has proposed to continue to pay the higher non-facility rate for telehealth services when provided to a patient at home. This goes against the previous recommendations by the Medicare Payment Advisory Commission to lower these rates post-pandemic.


Data Collection for Remote Monitoring


The rule has left the requirement for 16 days of data collection in a month unaddressed for remote patient monitoring. This aspect has been a point of concern for many stakeholders and is yet to be clarified.


The American Telemedicine Association’s Stance


The American Telemedicine Association has voiced its support for the proposed changes. In an 11-page letter to the CMS, Kyle Zebley, ATA senior vice president, mentioned that the rule is generally positive for the telehealth community. However, they urged CMS to address concerns about maintaining the confidentiality of healthcare providers' home addresses, which is especially relevant for those offering mental health services.


Privacy Concerns for Physicians


During the COVID-19 Public Health Emergency (PHE), CMS allowed physicians to bill their practice address rather than their home address to maintain confidentiality. The new proposed rule doesn't extend this flexibility beyond 2023, thereby raising privacy and security concerns for providers.


The Road Ahead


While the proposed rules seem overwhelmingly positive for the growth and accessibility of telehealth services, some aspects, like the data collection requirements and privacy concerns, still need to be ironed out. With the window for public comment closing soon, healthcare providers and stakeholders should actively participate in the process to ensure that the final rules are as comprehensive and beneficial as possible.


In conclusion, the proposed changes for 2024 by CMS indicate a significant step towards making telehealth a more integrated part of the healthcare system in the United States. With the pandemic changing the landscape of healthcare delivery, these rules come at a crucial time to solidify the gains made in telehealth services.


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