Telehealth: Before, During, and After the Public Health Emergency

Telehealth has become a crucial tool for delivering healthcare services during the ongoing COVID-19 pandemic. It has enabled healthcare providers to deliver care remotely, without the need for in-person visits, thereby reducing the risk of exposure to the virus. Telehealth has also made healthcare more accessible to patients in remote or underserved areas and those with mobility issues. However, telehealth billing has been a challenge for healthcare providers, especially during the public health emergency. In this article, we will explore telehealth billing before, during, and after the public health emergency.

Before the Public Health Emergency:
Before the pandemic, telehealth services were not covered by all insurance plans, and the reimbursement rates for telehealth services were lower than in-person visits. The reimbursement for telehealth services was also dependent on the state, the insurance plan, and the type of service provided. Therefore, healthcare providers faced a significant financial barrier to adopting telehealth services. Billing for telehealth services was also complicated, as it required navigating complex coding rules and billing procedures.


During the Public Health Emergency:
On January 27, 2020, the Public Health Emergency (PHE) was declared by Secretary of Health and Human Services. Since then, it has been renewed 14 times, with the final renewal being on February 11, 2023. The PHE is set to expire at midnight on May 11, 2023. The Centers for Medicare & Medicaid Services (CMS) have expanded use and other allowances, some which are due to expire on May 11, 2023, December 31, 2023, and December 31, 2024. The COVID-19 pandemic led to a surge in demand for telehealth services, and the government responded by expanding coverage for telehealth services and increasing reimbursement rates. CMS issued temporary waivers that allowed healthcare providers to bill for telehealth services at the same rate as in-person visits and waived many of the regulatory requirements for telehealth services. These changes made it easier for healthcare providers to deliver telehealth services and receive reimbursement for their services.

However, billing for telehealth services during the public health emergency was still complicated. Healthcare providers had to navigate the different rules and requirements for each insurance plan and state. They also had to use the correct codes and modifiers to ensure accurate billing. Failure to use the correct codes and modifiers could result in denied claims and delayed payments.

After the Public Health Emergency:

As the COVID-19 pandemic recedes, the temporary waivers and expanded coverage for telehealth services are set to expire. However, The Centers for Medicare & Medicaid Services (CMS) have expanded use and other allowances, some which are due to expire on May 11, 2023, December 31, 2023, and December 31, 2024. The government is currently reviewing the regulations around telehealth services and considering which changes to make permanent. It is likely that some of the temporary changes, such as the expansion of coverage and reimbursement rates, will become permanent. However, it is also possible that some of the regulatory requirements that were waived during the public health emergency will be reinstated.

Billing for telehealth services after the public health emergency is likely to be more complicated than before the pandemic, but less complicated than during the public health emergency. Healthcare providers will need to stay up to date on the regulations and requirements for telehealth services in their state and for each insurance plan they work with. They will also need to ensure they use the correct codes and modifiers for accurate billing.

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