Telehealth services billing unchanged at least through 2023

Q: Are there any changes to the telehealth billing in 2023?

A: For CY 2023, Medicare is finalizing a number of policies related to services, including making several services that are temporarily available as telehealth services for the Public Health Emergency (PHE) available at least through CY 2023. This allows additional time for the collection of data to help in determining whether or not Medicare will include service(s) as permanent additions to the Medicare Telehealth Services List. Centers for Medicare and Medicaid Services (CMS) has finalized their proposal to extend the duration of time that services are temporarily included on the telehealth services list during the PHE for at least a period of 151 days following the end of the PHE.

This confirms CMS' intention to implement the telehealth provisions to ensure a smooth transition after the end of the PHE. These policies, such as allowing telehealth services to be furnished in any geographic area and in any originating site setting (including the beneficiary’s home); allowing certain services to be furnished via audio-only telecommunications systems; and allowing physical therapists, occupational therapists, speech-language pathologists, and audiologists to furnish telehealth services, will remain in place during the PHE for 151 days after the PHE ends.

As a reminder, under this final provision, they will allow physicians and practitioners to continue to bill with the place of service (POS) indicator that would have been reported had the service been furnished in-person.These claims will continue to require the modifier 95 (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) to identify them as services furnished as telehealth services. Claims can continue to be billed with the place of service code that would be used if the telehealth service had been furnished in-person through the later of the end of CY 2023 or end of the year in which the PHE ends.

The Telehealth Originating Site Facility Fee has been updated for CY 2023, which can be found with the list of Medicare Telehealth List of Services at the following website:https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.

You can also find the listing of the telehealth services included in this ruling at:

List of Telehealth Services for Calendar Year 2023 (ZIP) - Updated 11/02/2022

Renee Dowling is a compliance auditor at Sansum Clinic, LLC, in Santa Barbara, California.