Telehealth coverage and policy changes during COVID-19
Summarizes evolving federal, state, Medicaid, Medicare Advantage, and private payer telehealth policy changes and guidance during the COVID-19 public health emergency; intended for payers, providers, and policy stakeholders monitoring reimbursement, licensing, and modality changes.
Medicare temporarily removed geographic and originating site restrictions allowing the home to be an eligible originating site under the COVID-19 waiver.
Medicare clarified that eligible services under the waiver include all services already eligible under Medicare telehealth reimbursement policies.
Medicare did not expand the types of providers eligible for reimbursement under the telehealth waiver; existing eligible provider list remains.
HHS OCR is exercising enforcement discretion and will waive penalties for good faith use of non-public-facing communication technologies for telehealth during the emergency.
DEA allowed issuance of controlled substance prescriptions via telemedicine without prior in-person evaluation while the public health emergency designation remains in effect, subject to conditions.
Medicare Advantage organizations were informed they may expand telehealth coverage and CMS will exercise enforcement discretion while the emergency persists.
Telehealth Coverage Changes During the COVID-19 Emergency
During the COVID-19 public health emergency, Medicare telehealth policies were expanded and Medicare Advantage and state Medicaid programs were given flexibility. Summarized below are the key coverage changes and operational notes that apply to Medicare Fee-for-Service (FFS), Medicare Advantage (MA), and Medicaid.
ALL of the following
- Medicare Fee‑for‑Service: geographic and originating site limitations removed so telehealth can be provided regardless of the beneficiary’s location, including the home. Newly eligible originating sites will not receive an originating site facility fee.
Implements HR 6074 telehealth waiver (effective March 17, 2020).
- Medicare Fee‑for‑Service: all services currently eligible under Medicare telehealth reimbursement policies are included in the COVID‑19 waiver (see Medicare list of eligible codes).
Waiver applies to services on CMS’s eligible telehealth code list.
- Medicare Fee‑for‑Service: the waiver does not expand the list of eligible providers — only existing Medicare‑recognized provider types remain eligible for reimbursement.
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