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Charting a New Course Post-PHE

From the College  |  May 23, 2023

Frequently Asked Questions

My patient lives in a different state than where I practice. Can I still provide care?

Upon the expiration of the PHE, cross-state license rules and requirements reverted back to the states. Throughout the PHE, many states updated their telehealth policies, including licensure regulations. The Center for Connected Health Policy has an overview of state regulations as they relate to telehealth, including any licensure updates.

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When will the telehealth extension end?

The Consolidated Appropriations Act of 2023 extended most telehealth flexibilities until December 31, 2024. It is expected that the CMS will address which flexibilities will become permanent in upcoming regulations.

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Does the reimbursement for telehealth remain the same as in-office visits?

Currently, reimbursement parity for in-office and telehealth visits will continue through 2023. Without additional rulemaking, reimbursement will be based on facility rates, resulting in reimbursement aligned with pre-PHE rates.

Are supervision rules the same for nurse practitioners and physician assistants?

Current regulation allows for virtual supervision through December 31, 2023. Without further rulemaking, rules will return to the pre-PHE requirement that the supervising physician must be physically present in the office. The ACR will continue to monitor upcoming regulations for any changes.

Will we be able to provide telehealth after 2024?

The CMS recognizes the role telehealth now has in the healthcare system. Currently, the flexibilities have been extended through 2024. In previous rules, the CMS has indicated that more telehealth services will be permanently covered. We await the forthcoming Physician Fee Schedule for updates on new telehealth coverage policies.  

Can I do audio visits only?

Reimbursement for audio-only visits has been extended through December 31, 2024. Note that, as with reimbursement parity for audio-visual visits, this will expire at the end of 2023 without further rulemaking.

Private Payers

It should be noted that, while the telehealth flexibilities remain for Medicare and Medicaid programs as noted above, private payers are now able to make different policies related to coverage of telehealth services.

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Filed under:Practice Support Tagged with:COVID-19telehealthU.S. public health emergency

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