Telehealth Reimbursement Authorities for Medicare Set to Expire

Action: On September 30, broad Medicare telehealth reimbursement flexibilities first enacted during the COVID-19 pandemic will expire, and the previous rules generally limiting telehealth reimbursement to providers or facilities in rural areas will return. In addition, temporary eligibility for many clinicians and audio-only services will end. With telehealth having become an integral part of health care delivery during and following the pandemic, whether the broad Medicare reimbursement policy resumes could have significant implications for delivery of care and cost not only for Medicare beneficiaries but also throughout the system.

Trusted Insights for What’s Ahead^®

• Pandemic-era laws first authorized changes to Medicare coverage of telehealth in March 2020. These measures allow reimbursement to providers covering all Medicare beneficiaries to receive certain care at home rather than only in rural areas, authorize audio-only visits when video technology was not feasible, permit Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) to serve as distant site providers, and broaden the range of clinicians eligible to furnish telehealth services.
• During and after the pandemic, many private insurers extended reimbursement to match the Medicare policy, though state rules on the practice of medicine may prohibit certain interstate telehealth services.
• Congress has repeatedly extended these flexibilities, often through annual appropriations bills. The Continuing Resolution passed by the House extends these flexibilities through November 21. The Congressional Budget Office scored the 2023 extension at $2.4 billion annually and the 2024 proposal for extension at $4 billion for a two-year extension.
• For behavioral health services, Congress has already made certain flexibilities, including home-based care, repeal of geographic limitations, and audio-only services, permanent. In addition, certain telehealth services will remain generally available after September 30, including monthly End-Stage Renal Disease visits for home dialysis and certain care for acute stroke. Certain Medicare Advantage plans will also continue to cover telehealth services under the provision of their contracts with beneficiaries.
• A proposal to make the Medicare telehealth changes permanent enjoys bipartisan support and endorsement by the American Medical Association.