Effective today, many of the telehealth flexibilities granted during the COVID-19 public health emergency have expired. Because Congress failed to pass a continuing resolution last night, this has created a telehealth cliff for many Medicare beneficiaries across the country.Here’s what this expiration means for psychiatrists and mental health care:
- Based on previous shutdowns, the Centers for Medicare and Medicaid Services (CMS) will continue processing Medicare claims, and Medicaid will maintain its payments to states.
- During a shutdown, CMS normally suspends oversight activities of its major contractors, including Medicaid Advisory Committees (MACs). While not guaranteed, suspension of these activities could affect a response to provider complaints related to MAC performance.
- The in-person visit waiver has expired. Starting today, patients must have had an in-person mental health visit with that provider (or a same-specialty provider in their group) within six months before initiating telehealth, and then at least annually thereafter.
- There are two exceptions to the annual in-person requirement, though both require a clear justification documented in the patient’s medical record:
- Patients who already get telehealth behavioral health services and have circumstances where in-person care may not be appropriate.
- Groups with limited availability for in-person behavioral health visits have the flexibility to arrange for practitioners to provide in-person and telehealth visits with different practitioners, based on availability.
- The waiver that allowed audio-only telehealth for most mental/behavioral health services (i.e., two-way, real-time audio) will remain permitted under Medicare.
- Telehealth visits for mental health services will not lose broader location and geographic flexibilities; however, the ability for Medicare patients to receive telehealth for other health issues at home may revert to pre-pandemic restrictions.
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