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COVID-19 and the Impact on Telehealth Services

With the onset of the coronavirus (COVID-19) pandemic, the health care community has understandably been focused on diagnosing and treating patients with COVID-19. However, other patients, including higher-risk Medicare beneficiaries who still require various essential medical services, are encouraged to stay at home during this time when many health care facilities are overcrowded.

In order to address this problem, lawmakers and regulators have taken steps to increase the Medicare coverage of telehealth, or telemedicine, services. Telehealth, or telemedicine, refers to the remote delivery of health care services via telephone, Internet or other telecommunications technologies and can be utilized for services such as common office visits, preventive health screenings and mental health counseling. Recent policy changes have temporarily relaxed restrictions on where and by whom telehealth services can be provided, making them much more accessible during the current public health emergency (PHE). The policy change highlights are discussed further below.

Waiver of Originating Site Requirement

Usually, Medicare covers telehealth services only if the patient receives those services at  an “originating site,” one of several specified types of medical facilities in a qualifying rural area. As permitted by Congress, the Centers for Medicare & Medicaid Services (CMS) has waived this site requirement, retroactive to March 1 and throughout the duration of the PHE. This allows reimbursable telehealth services to be received virtually anywhere, rural or urban, including patients’ homes, nursing homes and skilled nursing facilities.

New or Existing Patients

Originally, the waiver above permitted only those patients who had already established a relationship with the provider to be eligible for the expanded telehealth services. This requirement has been relaxed by Congress, permitting services to be provided to both new and existing patients. However, for certain telehealth services under some states’ laws, an established relationship may still be required.

Expanded List of Services and Providers

CMS has expanded the list of Medicare-reimbursable telehealth services from March 1 through the end of the PHE.  The full list, which identifies the services that are temporary additions, is available on the CMS website.  Additionally, the U.S. Drug Enforcement Administration (DEA) has temporarily relaxed restrictions on the ability of practitioners to issue prescriptions for controlled substances via telehealth platforms. The normally required in-person medical evaluation for such prescriptions is waived during the PHE as long as certain conditions are met. These prescriptions are, of course, subject to state law.

During the PHE, all practitioners eligible to bill Medicare may provide and receive reimbursement for telehealth services.  This includes physical therapists, occupational therapists and speech language pathologists.  Prior to the PHE, subject to applicable state law licensure and practice requirements, only physicians, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologists, clinical social workers, registered dietitians and nutrition professionals qualified.

Additionally, during the pandemic, CMS is now permitting the reimbursement of federally qualified health clinics (FQHCs) and rural health clinics (RHCs) for telehealth services.

Audio vs. Video

Normally, telehealth services are required to utilize technology that offers two-way, real-time audio and video communications between the practitioners and patients. During the PHE, however, CMS has waived the video requirement for certain audio-only telephone evaluation and management services, behavioral health counseling and educational services.

The above are just a few of the recent changes affecting Medicare reimbursement for telehealth services due to the COVID-19 pandemic.  These changes are currently temporary; there will likely be additional changes or guidance in the coming months.

For more information contact Anne Beason at 312.670.7444. Visit to learn more about our Health Care Group.

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