Billing Medicare and Private Payers for Telehealth Visits: What to Expect Post-Public Health Emergency

The American Medical Association (AMA) and many other organizations are actively advocating for continued support of telehealth post-pandemic. That said, healthcare providers and practice leaders need to anticipate and prepare for a return to more standardized regulation after the public health emergency (PHE) is lifted.

The Centers for Medicare and Medicaid Services (CMS) is expected to issue new rules for telehealth in the release of the 2021 Physician Fee Schedule on or after January 1, 2021. Today, Medicare reimburses for specific services when delivered via live video. These new rules are expected to specify what Medicare will cover regarding telehealth services, how those services must be billed going forward, and what documentation is required to be reimbursed. It is probable that private payers will adopt these Medicare rules, although it is unknown how quickly they may follow suit. It can be expected that post-PHE, payers will enact policies to limit the scope of telehealth coverage.

Providers must review these new Medicare telehealth billing rules, individual payer websites for any changes in telehealth policies for 2021, as well as any state-specific requirements. To see the state-specific policies, providers can check the Center for Connected Health Policy State Telehealth Laws and Reimbursement Policies Report.ⁱ While the Office of Inspector General (OIG) has deferred random audits during the emergency, expect them to resume after the PHE. 

Staying Ahead of Change

How can telehealth providers prepare for the changes expected to come at the end of the public health emergency? 

1. Consider what changes need to be made to manage an increased volume of telehealth visits. 
2. Review strategic plans and ensure the ability to meet the pre-PHE telehealth requirements.
3. Plan for probable changes. 
4. Check which payers require providers to be registered in-network to be covered and take steps to become a member of those networks that make sense for your organization.

In addition, advocate for the right changes. Comment on rules during the open comment period. Use technology to make the reimbursement process more effective. For example, use patient demographics verification and insurance coverage discovery and eligibility software to maximize reimbursement.

Read the full article for provider considerations and tips for moving forward post-PHE.