CAA, 2023 Extends Medicare Telehealth Policy Through 2024

Sarah Hohman, NARHC Director of Government Affairs

Congress released draft text this week for the Consolidated Appropriations Act of 2023, also known as the yearly “Omnibus” package which will fund the federal government for the remainder of Fiscal Year 2023.

Notably, Congress extended several Medicare telehealth flexibilities, currently set to expire on the 152nd day after the end of the Public Health Emergency (PHE) to now continue through December 31, 2024 (if the Public Health Emergency ends before 12/31/2024).

This legislation would allow RHCs to continue as telehealth distant site providers, under current G2025 policy, through 12/31/2024. If passed as released, this bill would also delay in-person requirements for mental health services done via telehealth until January 1, 2025 (or the end of the PHE, if later).

“NARHC will continue to advocate for normal payment and normal coding rules pertaining to telehealth visits in RHCs, like was granted for mental health telehealth” said Nathan Baugh, NARHC Executive Director. “However, we hope this extension offers providers continued confidence that telehealth is here to stay.”

We remain supportive of many of these telehealth provisions and the increased flexibility and access that telehealth services have brought to many communities served by RHCs yet continue to emphasize our concerns regarding the inequitable payment policies for safety-net providers perpetuated by the G2025 policy.

While fee-for-service providers have coding and reimbursement parity between in-person and telehealth services, RHCs and FQHCs utilize a “special payment rule” and bill G2025 for all telehealth services. This is reimbursed at one rate of $97.24 in 2022, a substantially lower reimbursement than the All-Inclusive Rate many RHCs receive for in-person encounters. G2025 will be reimbursed at $95.88 in 2023, further increasing the disparity between FFS and RHC/FQHC reimbursement for telehealth.

It's important to note that this remains a temporary policy as Congress and the Administration gathers further data on the utilization, cost, and outcomes associated with telehealth before establishing permanent policy. Earlier this year, various Members of Congress introduced pieces of legislation that would correct these reimbursement disparities by establishing parity between in-person visits and those done via telehealth, like was established for mental health telehealth.

In the new Congress, we will continue to advocate on behalf of changes to the reimbursement provisions for safety-net providers being a component of these continued discussions and will keep the RHC community updated on any developments. For current telehealth billing policy, please visit NARHC.org.

We encourage you to stay up to date on key RHC news on NARHC.org and contact Sarah Hohman, NARHC Director of Government Affairs, Sarah.Hohman@narhc.org, or Nathan Baugh, NARHC Executive Director, Nathan.Baugh@narhc.org with any questions or concerns.