Recently, the Centers for Medicare & Medicaid Services (CMS) released its updates for the calendar year (CY) 2022. Medicare Physician Fee Schedule (MPFS) Final Rule, for CY 2022 was released by CMS, going into effect from Jan. 1, 2022. The Final Rule included changes in the physician fee schedule and billing of physician assistant services, updates of policy changes for several services included under Medicare, a number of COVID-19 related changes that will be extended or be made permanent with telehealth being an area of key focus.

This article highlights the important modifications made by CMS in their CY 2022 announcement and also some relevant coding updates. It is a 3 series article that intends to provide sufficient data to physicians, facilities and healthcare organizations to aid them in accurate and swift submission of claims for the services they provide to Medicare beneficiaries. A knowledge of these updates helps receive proper reimbursement for these services by ensuring clean claim submission and averting claim denials at the same time provide quality healthcare, accessible to all patients.

Telehealth Inclusions for Mental Health Services

With an intent to make mental healthcare available to all, including people in areas with poor broadband infrastructure and in rural communities, CMS has included broader coverage of telehealth services for behavioral health in CY 2022. Here are some key highlights:

• CMS would remove geographic restrictions around telehealth visits for mental health services. Medicare would cover visits in patients’ homes, including for diagnosis, evaluation or treatment of mental health conditions. This includes temporary lodging facilities such as hotels, homeless shelters or nursing homes that are a short distance from the patient’s actual home.

• CMS would allow audio-only communication for telehealth mental health services to established patients located in their homes for purposes of diagnosis, evaluation, or treatment of mental health disorders, if the patient doesn’t have the technical capacity or the availability of real-time audio and visual interactive telecommunications, or they don’t consent to the use of real-time video technology.

• To avail this, specifically the patient must have had a Medicare-covered in-person visit with the provider (or a colleague of the provider within the same specialty and group) within six months prior to the delivery of the telehealth services.

• Subsequent telehealth interactions must occur within 12 months of the in-person visit, unless the patient and provider agree that the risks and burdens of an in-person visit are outweighed by the benefits of telehealth. This determination must be documented in the patient’s record, and the provider must verify that the patient is able to obtain necessary point-of-care testing.
   
• The reimbursement of tele mental health services will continue even after the public health emergency ends following changes made through new federal legislature.

Telehealth Mental Health Services Coding Updates

•  2 additional modifiers for CY 2022 related to telehealth mental health services have been added. The modifiers are:

FQ - A telehealth service was furnished using real-time audio-only communication technology

FR - A supervising practitioner was present through a real-time two-way, audio/video communication technology

•  Place of Service (POS) codes 02 (telehealth services not provided at patient’s home) and 10 (telehealth services provided at patient’s home) are in use in the wider health care insurance industry but CMS continues to recognize the previous POS 02 code as Telehealth (The location where health services and health related services are provided or received, through a telecommunication system)

Use of telehealth services during the public health emergency provided means to allow health care access to one and all. Although the future of telehealth seems somewhat unsettled, the changes in the Final Rule signal a positive move for Medicare beneficiaries as regulators acknowledge the potential benefits of these alternate methods of delivering care.

Another important update made by CMS is the change in conversion factor (CF) used to calculate fee-for-service payments to physicians to $34.6062 for CY 2022. While this represents a 0.82% cut from the CY 2021 CF of $34.8931, it reflects an increase from the initially announced CY 2022 physician CF of $33.5983.