Audio Only Services in the Year 2022
On November 2, 2021, the Centers for Medicare and Medicaid Services (CMS) issued the final rule on the Medicare physician fee schedule detailing how health care services offered by psychologists and other providers will be delivered and reimbursed in 2022. Below are some of the key issues of interest to psychologists. Reimbursement for audio-only services for mental health will continue after the public health emergency ends.
Below mentioned changes made through new federal legislation, CMS will allow audio-only services to be provided for the diagnosis, evaluation, and treatment of mental health conditions and substance use disorders after the public health emergency (PHE) ends. The originating site requirement will not apply when patients receive these services through audio-only devices in their homes, with the definition of the home being viewed broadly to include temporary lodging, such as a hotel. However, Health Behavior Assessment and Intervention services will be excluded from audio-only coverage once the PHE ends. Absent new federal legislation, health behavioral services, feedback sessions for psychological and neuropsychological testing evaluations, and other services will not be allowed via audio-only technology after the PHE ends.
Under the final rule, once the PHE ends, audio-only telehealth services for mental health and substance use disorder (SUD) services will require an in-person visit within six months of the initial telehealth visit and within 12 months of any subsequent telehealth visit. Providers will be able to request exemptions if they believe it would benefit the patient not to meet in person. CMS will not require additional documentation but providers furnishing audio-only services will need to use a billing modifier on claims to indicate that the patient did not have access to two-way audio-visual communication technology or did not consent to its use.
Federally Qualified Health Centers and Rural Health Clinics
CMS will allow patients in Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) to receive mental health and SUD services through audio-communications technology. The patient must have received an in-person service within six months of the initial telehealth service, and the telehealth visit must be billed with a modifier. A modifier consists of two characters and is listed on the claim form to provide additional information about the service. Behavioral health services in RHCs and FQHCs will not be eligible for reimbursement as a telehealth service unless provided with two-way audio-visual communications technology.