In what now amounts to a total reversal of its initial post-public health emergency policies around telehealth, the U.S. Centers for Medicare & Medicaid Services has listened to APTA and other organizations and will allow the provision of telehealth services across a range of facilities, just as they were permitted during the PHE. The major advocacy win means that PTs in skilled nursing facilities, home health, and rehab agencies can continue to provide remote services under Medicare Part B — although CMS has yet to say when those allowances might end.
As with an earlier clarification around hospital-based settings, the latest news from CMS comes by way of an FAQ document on post-PHE policies (see question 22). In the latest iteration of the resource, CMS says that therapy providers working across the range of facility settings can continue to provide telehealth services as they did via waivers granted during the PHE. The announcement follows an earlier, more limited reversal that applied only to telehealth provided in hospital-based facilities.
Originally, CMS' post-PHE telehealth policies appeared to exclude any facility-based provision of telehealth from coverage if that facility used a particular claim form, the UB04. APTA was among the first organizations to call attention to the inconsistencies and patient access problems with this position, and was joined by the American Speech-Language-Hearing Association and the American Occupational Therapy Association in advocacy to press CMS to maintain telehealth allowances across the board. While CMS warned that it could take some time to provide definitive guidance, in the end the agency's decisions arrived relatively quickly.
While the guidance from CMS is clearly good news for the physical therapy community and its patients, one major detail was left out — namely, if and when these telehealth allowances would end. In its earlier hospital-based telehealth decision, CMS stipulated that telehealth could continue through the end of 2023 in those settings. That ending date, opposed by APTA, doesn't jibe with telehealth end dates for PTs and PTAs in private practices, which are expected to be extended through Dec. 31, 2024. APTA, ASHA, and AOTA are pushing for answers, which CMS will most likely provide when it issues the 2024 proposed Medicare Physician Fee Schedule. Meanwhile, APTA and other organizations are pushing for lawmakers to permanently include PTs and PTAs in the list of providers allowed to provide telehealth services under Medicare.
"The conversations we were able to have with representatives from [the U.S. Department of Health and Human Services] were extremely beneficial in helping CMS understand why it's so important to maintain telehealth allowances after the PHE, particularly for patients in rural and underserved communities," said Kate Gilliard, JD, APTA's director of health policy and payment. "We're extremely happy that CMS sees the value in continuing coverage."