Currently, during the public health emergency (PHE), FQHCs and other distant site telehealth providers may bill Medicare for certain telehealth services using audio-only telephone and CMS expanded the telehealth codes for the duration of the PHE to include telephonic E/M services (CPT 99441-99443). CMS sought comment on whether/how CMS should continue coverage of audio-only telephonic E/M services after the PHE and NACHC recommended that CMS continue to recognize these services as telehealth services. Instead, CMS finalized its proposal to eliminate those codes as telehealth codes and instead add a new G-code to the “virtual communication services” bundles payment to include an 11-21 minute medical discussion via audio-only phone (G2252), not limited to the PHE “Category 3 telehealth services.” Category 3 services are those that were added to the Medicare telehealth code list during the PHE for which there is likely to be clinical benefit when furnished via telehealth, but for which there isn’t yet evidence available to make them a permanent addition. CMS will now recognize these services on the telehealth list until the end of the calendar year in which the PHE ends. Examples include certain psychological and neuropsychological testing and physical and occupational therapy services.
