In its proposed 2022 Medicare physician fee schedule released on Tuesday, the Centers for Medicare & Medicaid Services has included plans to expand access to telehealth for behavioral healthcare.
The agency is proposing to implement recently enacted legislation that allows patients to access telehealth services for the treatment of mental health disorders in any geographic location and in their homes.
Along with this change, CMS is proposing — for the first time — to allow Medicare to pay for mental health virtual visits when they are provided by rural health clinics and federally qualified health centers.
But CMS has included a requirement wherein practitioners providing behavioral telehealth services must conduct an in-person visit within the six months before the first virtual visit, and at least once every six months after.
In addition, the agency wants to allow audio-only communication technology to be used for diagnosis, evaluation or treatment of certain mental health disorders, as opposed to requiring both audio and video equipment. This includes counseling and therapy services provided through opioid treatment programs.
“The changes we are proposing will enhance the availability of telehealth and similar options for behavioral healthcare to those in need, especially in traditionally underserved communities,” said CMS Administrator Chiquita Brooks-LaSure, in a news release.
Another significant change proposed in the payment rule centers on remote patient monitoring.
CMS is considering introducing new remote therapeutic management services, which are built upon the existing remote patient monitoring codes but have several important policy differences, including how data is collected and the nature of the data collected, said Jake Harper, an associate at law firm Morgan Lewis, in an email.
“Depending on how policies for these codes are solidified, this could dramatically change the burgeoning RPM/RTM industry,” he said.
Aside from the proposed changes to coverage of telehealth and remote patient monitoring services, CMS is aiming to advance its value-based Quality Payment Program. The agency wants to require clinicians to meet a higher performance threshold to be eligible for incentives.
The agency has also proposed its first seven MIPS Value Pathways, which are subsets of measures and activities used to meet reporting requirements for the Merit-based Incentive Payment System. The clinical areas covered by the pathways are rheumatology, stroke care and prevention, heart disease, chronic disease management, lower extremity joint repair, emergency medicine and anesthesia.
Further, in a more controversial move, CMS is planning to reduce the physician fee schedule conversion factor to $33.58 for each relative value unit, down from $34.89. Medicare pays physicians based on the conversion factor.
The Medical Group Management Association “is concerned about the potential impact of the proposed 3.75% reduction to the conversion factor,” said Anders Gilberg, senior vice president of government affairs at the association, in an emailed statement.
The group plans to “seek congressional intervention to avert the cut,” he said.
The entire 1,747-page proposed rule can be viewed here.
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