• The Center for Connected Health Policy (CCHP) has created this video primer on how Medicare policy gets created, who can act to make changes and the difference between "telehealth" and "communications technology based services (CTBS)".

Medicare Telehealth Billing Resources:

  • The Center for Medicare and Medicaid Services (CMS) has created a List of Telehealth Services payable under the Medicare Physician Fee Schedule when furnished via telehealth.  This list is updated each year.  Everything on the list is covered through the end of Calendar Year (CY) .  Updates for the upcoming Calendar Year will be addressed through the normal Physician Fee Schedule update process.  The fee schedule is updated annually and takes effect on January 1 of each year.  Proposed changes are published in the Federal Register by November of each year.
    • Any interested party (public or private) may submit requests for adding services to the list of Medicare telehealth services. Requests are due to CMS by February 10 of each year to be considered for the current year cycle of rulemaking.
    • Added in the Consolidated Appropriations Act of 2023 and the CY2024 Physician Fee Schedule, Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs) are now considered eligible Medicare practitioners and will be eligible to be reimbursed by Medicare for telehealth services beginning January 1, 2024.

Resources Related to the Unwinding of the Public Health Emergency (PHE):  During the PHE, individuals with Medicare had broad access to telehealth services, including in their homes, without the geographic or location limits that usually apply as a result of waivers issued by the Secretary, facilitated by the Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020, and the Coronavirus Aid, Relief, and Economic Security Act. “Telehealth” includes services provided through telecommunications systems (for example, computers and phones) and allows health care providers to give care to patients remotely in place of an in-person office visit.

Medicare Advantage plans may offer additional telehealth benefits. Individuals in a Medicare Advantage plan should check with their plan about coverage for telehealth services. Additionally, after December 31, 2024 when these flexibilities expire, some Accountable Care Organizations (ACOs) may offer telehealth services that allow primary care doctors to care for patients without an in-person visit, no matter where they live. If your health care provider participates in an ACO, check with them to see what telehealth services may be available.

The PHE officially came to an end on May 11, 2023.  Here are a number of resources to help you prepare for the unwinding of the PHE which takes place in different stages between May 11, 2023 and December 31, 2024.  Guidance and policies continue to be somewhat of a moving target so check back frequently for updates and changes and make sure you check the update date for all documents!

A Few Frequently Asked Questions About Medicare and Telehealth:  

  • Can a Provider be located out of the country (either temporarily or permanently living abroad) and bill Medicare for telehealth visits?

The short answer is No.  According to the Code of Federal Regulations:

Except as specified in paragraph (b) of this section, Medicare does not pay for services furnished outside the United States. For purposes of this paragraph (a), the following rules apply:

(1) The United States includes the 50 States, the District of Columbia, Puerto Rico, the Virgin Islands, Guam, American Samoa, The Northern Mariana Islands, and for purposes of services rendered on board ship, the territorial waters adjoining the land areas of the United States.

(2) Services furnished on board ship are considered to have been furnished in United States territorial waters if they were furnished while the ship was in a port of one of the jurisdictions listed in paragraph (a)(1) of this section, or within 6 hours before arrival at, or 6 hours after departure from, such a port.

(3) A hospital that is not physically situated in one of the jurisdictions listed in paragraph (a)(1) of this section is considered to be outside the United States, even if it is owned or operated by the United States Government.

  • If a Provider offers telehealth services from their home, how do they enroll their practice location without their home address and personal phone number being made public on their profile?

On March 4, 2024, CMS published a notice in the Federal Register clarifying changes that have been made to the information providers are required to submit to the National Plan and Provider Enumeration System (NPPES) that is necessary to obtain and maintain a National Provider Identifier (NPI). Currently, one of the pieces of information that must be collected includes the provider’s address, both a mailing address and a location address, the latter of which originally must not be a post office box. This information can sometimes be publicly accessible. In the notice CMS writes,

Since the publication of the NPI final rule, health plans, Medicare, and Medicaid programs, have expanded coverage for telehealth services.[6] As such, there are now a number of individual (Entity type code = 1) providers, such as behavioral health service providers, who exclusively furnish telehealth services from the providers' homes. In some instances, providers who exclusively furnish telehealth services from their own homes may not have a provider address location other than their home address. We understand that providers who furnish telehealth services exclusively from their homes often enter a post office box as their provider mailing address into NPPES when applying for an NPI. Given the prohibition on including a post office box for the provider location address data elements, they enter their home addresses into NPPES to satisfy the provider location address data elements and obtain an NPI.

In acknowledgment of the concerns over providers’ home addresses possibly being accessible to the general public, this new notice from CMS is now clarifying that while it will still require the provider location address, it will allow for that to be either a post office box or personal mailbox offered by a private delivery service if the provider’s NPI is entity type code = 1 and does not have a physical location other than their home. CMS cites as a specific example a provider that exclusively provides services via telehealth from their home.  This notice is effective April 3, 2024.