Telemedicine Flexibilities Preserved in Medicare Fee Schedule
By Alisa Pierce Texas Medicine March 2024


Castroville family physician Mary Nguyen, MD, sees patients she’s known for years – for their entire lives, in fact.

Located about a 30-minute drive from San Antonio, Dr. Nguyen’s practice offers virtual appointment options for those who often can’t find the resources to come into the clinic, such as patients without reliable means of transportation or university students unable to travel home to continue their care.

Dr. Nguyen says the ability to treat these patients stems from telemedicine flexibilities implemented during the COVID-19 pandemic. “I’ve seen many of my patients since they were children,” she said. “As they’ve grown, so have their care needs. And those needs don’t go away when they leave the area.

“The ability to continue a patient’s care, wherever in Texas they’re comfortable, is a privilege I’ve feared would fade with the pandemic. I’m glad to see my fears are staved off – at least for now.”

The 2024 Medicare physician fee schedule (MPFS) extends several pandemic-era telehealth flexibilities, many of which impact physicians who treat rural patients and those with behavioral health needs, says Dr. Nguyen.

Those changes include:

• The expansion of telehealth originating sites to include any location in the U.S. where a patient is located at the time of a telehealth appointment, such as an individual’s home, through Dec. 31, 2024;

• A delay in requiring an in-person visit with a physician within six months prior to initiating mental health telehealth services and again at subsequent intervals, as well as similar requirements for rural health clinics (RHCs) and federally qualified health centers (FQHCs);

• The continued coverage and payment of telehealth services included in the Medicare telehealth services list until Dec. 31, 2024;

• Payment for telehealth visit services by occupational therapists and qualified physical therapists, qualified speech-language pathologists, and qualified audiologists;

• The continued payment for telehealth services furnished by RHCs and FQHCs established during the COVID-19 pandemic; and

• The addition of mental health counselors and marriage and family therapists as distant site practitioners for purposes of providing telehealth services.

“If you’re in a rural, underserved area with no mental health facility or physician available, and no telehealth options, that means you’re going months or longer without help,” Dr. Nguyen said. “The changes implemented by the fee schedule, like providing payment to a wider range of telehealth practitioners and allowing physicians to treat patients across the state, aid our mission to deliver behavioral health care.”

Other changes allow teaching physicians to use audio or video real-time communications technology at all residency training locations through the end of 2024 – an exception to a 2021 provision that, after the end of the pandemic, required teaching physicians to attend training sessions in person to bill for their services involving residents, including Medicare telehealth services. 

Protecting physician privacy

During the pandemic, CMS also allowed physicians to offer telehealth services from their homes without reporting their home address on their Medicare enrollment. That flexibility was set to expire Dec. 31, 2023.

Following staunch opposition by TMA, however, CMS will not require physicians to list their home address as a practice location on Medicare enrollment forms for another year when providing telehealth services, safeguarding their privacy and safety.

Houston internist Lisa Ehrlich, MD, says the flexibilities allowed physicians to provide a robust level of care without worrying about their safety.

“Removing the requirement to include our home addresses protects us from increased vulnerability and prevents the erosion of telehealth,” she said. “Imagine if a physician wanting to provide telehealth services needed to list their home address to do so. If they were fearful for their safety, they may avoid providing those services.”

TMA explained to CMS that, if address flexibilities were rescinded, a significant number of practices would need to change their billing protocols, coordinate with a Medicare administrative contractor, or possibly be subject to site inspections, adding to physicians’ already lengthy list of administrative responsibilities.

“TMA implores CMS to allow physicians to conduct visits as needed from locations other than their primary practice setting without having to add their home address to their Medicare enrollment form. This allows physicians to extend the hours they are available to patients without concern that their address will be made public or their Medicare enrollment form is updated,” TMA wrote in a Sept. 8 comment letter to the agency.

Heeding such concerns, CMS said in the MPFS final rule that it “will continue to permit the distant site practitioner to use their currently enrolled practice location instead of their home address when providing telehealth services from their home.” The agency also asked physicians for guidance in future rulemaking.

Dr. Ehrlich says she’s grateful for the changes she’s seen in the fee schedule but plans to confer with TMA experts as the year progresses.

“I appreciate that TMA is on top of changes that impact our practices, some we don’t even know are happening,” Dr. Ehrlich said. “Sometimes, it’s best to be wary – but not when TMA has our backs.” 

Last Updated On

March 05, 2024

Originally Published On

February 29, 2024

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Alisa Pierce

Reporter, Division of Communications and Marketing

(512) 370-1469
Alisa Pierce

Alisa Pierce is a reporter for Texas Medicine. After graduating from Texas State University, she worked in local news, covering state politics, public health, and education. Alongside her news writing, Alisa covered up-and-coming artists in Central Texas and abroad as a music journalist. As a Texas native, she enjoys capturing the landscape on her film camera while hiking her way across the Lonestar State.

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