Last Updated: Sep 5, 2024
Telehealth
CMS proposes providing coverage for audio-only telehealth under the scenario where the physician has video and audio capability, but the patient does not have access to video technology. When billing, CMS requires providers to utilize modifier 93, and for RHCs & FQHCs, use Medicare Modifier FQ.
They are also continuing to propose coverage for distant site telehealth while using the currently enrolled practice location instead of a home address when rendering telehealth from home. CMS proposes permanently defining Direct Supervision as involving real-time audio-video communications and extending this capability through 2025.
There is also a proposal to increase the Originating Site rate in line with the Medicare Economic Index Increase of 3.6% and, as a result, would increase this amount for code Q3014 to $31.04. CMS also proposes lifting frequency limits on telehealth for subsequent inpatient and nursing facility visits along with critical care consultations.
Supervision of Outpatient Therapy Services in Private Practices and Certification of Therapy Plans of Care With a Physician or NPP Order
Occupational Therapists in Private Practice’s (OTPP) and Physical Therapists in Private Practice’s (PTPP) supervision of Occupational Therapist Assistants (OTAs) and Physical Therapy Assistants (PTAs) is being proposed to change from Direct to General Supervision, allowing OTPPs and PTPPs to receive reimbursement for the care provided by OTAs and PTAs. OTPPs and PTPPs would still need to provide direct supervision to unenrolled Occupational Therapists (OTs) and Physical Therapists (PTs).
CMS also proposes allowing providers' (physicians or NPPs) signatures on the order or referral to be substituted as the signature on the treatment plan if the plan was not signed and returned to the therapist within 30 days. This exception can only be substituted for the initial certification of the patient’s treatment plan. The referral/order needs to be in the patient’s medical record.
Electronic Prescribing Requirements for Controlled Substances for a Covered Par D Drug or an MA-PD Plan
All controlled substances prescribed for Medicare Part D beneficiaries must be submitted electronically, and they must comply with this as soon as January 1st, 2025. Notices and educational resources will be sent to those who are non-compliant. An exception to this requirement involves providers who are prescribing less than 100 Part D controlled substances annually.
Medicare Payment for Preventive Services
CMS proposes increasing the coverage of Hepatitis B vaccinations by covering those who have received a complete series or have an unknown vaccination history. They also propose roster billing for mass immunizers for hepatitis B vaccine administration and that a physician’s order would not be required for the administration in Part B beneficiaries.
They’re also proposing to pay for PrEP coverage to assist with HIV infection prevention and for a drug that is listed under additional preventive services that do not have cost-sharing.