Medicare & Telehealth During COVID-19 Pandemic

Medicare & Telehealth During COVID-19 Pandemic

In March 2020 the Centers for Medicare and Medicaid Services (CMS) expanded the use of telehealth during the COVID-19 public health emergency.  Some requirements have been TEMPORARILY waived. 
Licensed mental health professionals who are enrolled in Medicare can be reimbursed for telehealth services provided:
  • To new or established Medicare beneficiary clients
  • To clients whether the client is in their own home or in any healthcare setting
  • From their own home (in addition to their office or another location)
  • Using technology allowing real-time, two-way interactive communication, beyond those allowed pre-COVID.  This includes smartphones with video chat technologies such as Apple FaceTime and Skype, as well as video conferencing that was permissible pre-COVID
  • For the duration of the public health emergency, using audio-only devices (e.g. landlines) for certain services  (including psychotherapy, opioid treatment and certain telephone evaluation and management services)
  • Internet-facing smartphone apps such as TikTok or Facebook Live, or chat rooms such as Slack, are still prohibited because they allow wide public access to the communication
  • Telehealth waivers will be effective until the public health emergency declared by the Secretary of Health and Human Services ends

Clinicians can bill for dates of service starting March 6, 2020.  Telehealth services are paid under the Physician Fee Schedule at the same amount as in-person services.  Medicare coinsurance and deductibles still apply for these services; however, the HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.

When providing mental health services using telehealth, clinicians are governed by the laws and regulations in Florida, as well as the state where the client is physically located.  Clinicians must contact the state where the client is located to learn about laws and regulations surrounding telehealth in that state.  It is important to remember that not every state has approved the provision of mental health services via telehealth, even during this public health emergency. 

The U.S. Department of Health and Human Services (HHS) will exercise enforcement discretion and waive penalties for most HIPAA violations against providers who serve patients in good faith through everyday communication technologies during this public emergency.

A.A. Ross Counseling provides a Telehealth Course that meets new legislative requirements for license renewal for LCSW, LMFT, & LMHC in Florida.  A Telehealth Course must be completed prior to the 3-31-23 renewal, then every alternate renewal thereafter.  This course can be substituted for an Ethics Course.