At the start of the pandemic, The Centers for Medicare and Medicaid Services (CMS) quickly passed emergency measures to allow flexibility for the medical community to adapt to the public health emergency (PHE) and to ensure they were able to deliver care effectively and safely. That resulted in a rapid expansion of telehealth, which has been well received by patients and providers alike.

As we look toward 2021 and to the hopes for the end of the COVID-19 pandemic, CMS has released guidelines for telehealth coverage post-pandemic.

Telehealth Services That Will Remain Permanent

These services are scheduled to become permanent effective January 1, 2021.

  • Group Psychotherapy
  • Domiciliary, Rest Home, or Custodial Care Services for Established Patients
  • Home Visits for Established Patients
  • Cognitive Assessment and Care Planning Services
  • Visit Complexity Inherent to Certain Office/Outpatient E/MS
  • Prolonged Services
  • Psychological and Neuropsychological Testing

Telehealth Services That Will Be Removed

These services will be removed when the PHE expires.

  • Initial nursing facility visits for all levels
  • Psychological and Neuropsychological Testing
  • Therapy Services, Physical and Occupational Therapy for all levels
  • Initial hospital care and hospital discharge day management
  • Inpatient Neonatal and Pediatric Critical Care, Initial and Subsequent
  • Initial and Continuing Neonatal Intensive Care Services
  • Critical Care Services
  • End-Stage Renal Disease Monthly Capitation Payment
  • Radiation Treatment Management Services
  • Emergency Department Visits, Levels 4-5
  • Domiciliary, Rest Home, or Custodial Care services for new patients
  • Home Visits for new patients, all levels
  • Initial and Subsequent Observation and Observation Discharge
  • Day Management

Telehealth Services, Requesting Comment

CMS is not currently proposing to add these services to the Medicare telehealth services list. They are, however, seeking comment on whether these services should be added. When considering the comments, CMS will assess whether there are increased concerns for patient safety if the services is delivered via telehealth, whether there are concerns about jeopardizing the quality of care if delivered via telehealth; and whether all elements of the service could be performed using telehealth.

  • Initial nursing facility visits for all levels
  • Psychological and Neuropsychological Testing
  • Therapy Services, Physical and Occupational Therapy for all levels
  • Initial hospital care and hospital discharge day management
  • Initial and Subsequent Inpatient Neonatal and Pediatric Critical Care
  • Initial and Continuing Neonatal Intensive Care Services
  • Critical Care Services
  • End-Stage Renal Disease Monthly Capitation Payment
  • Radiation Treatment Management Services
  • Emergency Department Visits, Levels 4-5
  • Domiciliary, Rest Home, or Custodial Care services, New
  • Home Visits, New Patient for all levels  
  • Initial and Subsequent Observation and Observation Discharge Day Management

To learn more about the services that will be covered, refer to the 2021 Physician Fee Schedule.

Additionally, an Executive Order on Improving Rural Health and Telehealth Access was released, which may result in continued and increased access to telehealth services for the 57 million Americans living in rural communities. The order has launched reports on:

  • A new payment model to ensure rural providers can provide quality care.
  • Improvements to communications infrastructure in rural communities to ensure access to care.
  • Review of existing and upcoming policy initiatives to eliminate regulatory burdens that limit the availability of providers; prevent disease through efforts to improve health outcomes; reduce maternal mortality and morbidity; and improve mental health.
  • Review the expansion of telehealth and flexibilities for providers during the PHE to determine if they should become permanent.