CMS Issues Interim Final Rule Allowing for Audio-Only Periodic Assessments by OTPs and Announces Second Round of Telehealth Changes In Response to COVID-19

On April 30, CMS issued an interim final rule, which becomes effective upon publication in the federal register, to allow periodic assessment furnished by OTPs (HCPCS code G2077) to be furnished during the public health emergency (PHE) for the COVID-19 pandemic via two-way interactive audio-video communication technology. In addition, in cases where beneficiaries do not have access to two way audio-video communications technology, the periodic assessments may be furnished using audio-only telephone calls rather than via two-way interactive audio-video communication technology, provided all other applicable requirements are met. CMS expects OTPs to use clinical judgment to determine whether they can adequately perform the periodic assessment over audio-only phone calls, and if not, then they should perform the assessment using two-way interactive audio-video communication technology or in person as clinically appropriate.  Regardless of the format that is used, the OTP should document in the medical record the reason for the assessment and the substance of the assessment.

CMS previously issued guidance on March 31 allowing for the therapy and counseling portions of the weekly bundles of services furnished by OTPs, as well as the add-on code for additional counseling or therapy (HCPCS code G2080), to be furnished using audio-only telephone calls rather than via two-way interactive audio-video communication technology during the PHE for the COVID-19 pandemic if beneficiaries do not have access to two-way audio/video communications technology, provided all other applicable requirements are met.

Also on April 30, CMS announced that it is broadening the list of reimbursable Medicare services conducted by audio-only telephone between beneficiaries and their doctors and other clinicians to include many behavioral health and patient education services. CMS is increasing payments for these telephone visits to match payments for similar office and outpatient visits. This would increase payments for these services from a range of about $14-$41 to about $46-$110. The payments are retroactive to March 1, 2020.

Read the interim final rule here.

Read CMS’ April 30th press release related to its second round of telehealth changes here.