Medicare Telehealth & What We Know Today

  • The CARES Act included Medicare telehealth flexibility for FQHCs and RHCs for the duration of the crisis. It authorizes Medicare reimbursement for health centers and rural health clinics as distant sites for the duration of the emergency, not reimbursed at PPS rate but instead “such payment methods shall be based on payment rates that are similar to the national average payment rates for comparable telehealth services under the physician fee schedule under section 1848.”
  • Since 2019, FQHCs could bill Medicare for virtual communication services (aka phone calls) using code GOO71. (This is in lieu of the codes 99441, 99442, and 99443, which only those providers who bill under the fee schedule can use.) The payment is around $14, and FQHCs cannot bill for it if the patient had a related evaluation/management service within the previous 7 days or has an on-site appointment within the next 24 hours. These services must be initiated by a patient and as long as the provider responding to the call is an employee or contractor of the health center, he or she does not have to be physically located at the health center while delivering these services. CMS also has an FAQ document on virtual communication.

On March 30 the Centers for Medicare & Medicaid Services (CMS) issued an array of new rules and waivers of federal requirements offering maximum flexibility to respond to the COVID-19 pandemic including a section entitled “Further Promote Telehealth in Medicare.” There is a provider-specific fact sheet on new waivers and flexibilities for FQHCs and RHCs but it does not address telehealth.