On January 1, 2022, the Centers for Medicare & Medicaid Services (CMS) implemented permanent changes in the Medicare Physician Fee Schedule that offer new possibilities to expand the scope of telehealth for mental health (MH) and substance use disorders (SUD) for Medicare patients. These changes are a direct response to recent increases in MH and SUDs over the last two years, which have been especially deadly in combination with the tsunami of synthetic opioids (namely fentanyl) that has cascaded across the United States.1
Amid the shelter-in-place regulations of the COVID-19 pandemic, telehealth emerged as a powerful tool. Telehealth can improve access to care, particularly among vulnerable populations who may lack funds for travel and care of dependents. For patients with SUDs, stigma may present further barriers to in-person care, which telehealth may help to alleviate.2 Not only do primary care clinics present an entryway into care for MH disorders, they increasingly receive a greater proportion and volume of visits for MH disorders than psychiatry offices.3
Those of us in general medicine have long been hampered in our efforts to expand access for our patients SUD and MH conditions by insufficient resources. With the new service code options provided by CMS, we can explore innovative ways of care delivery that leverage the expertise of a multi-disciplinary team. In the table, we lay out relevant Medicare telehealth service codes with the respective payments in relative value units (RVUs). RVUs translate to dollars by multiplying times the Medicare conversion factor, roughly $35.
Here Are the CMS Changes You Need to Know About
The patient can be located anywhere—whereas telehealth services were previously confined to dedicated spaces, telehealth services for MH and substance use care can be provided to patients who are home, or at another location including a shelter, car, or their place of work. State licensing restrictions still apply. Encounters should be clearly focused on MH/SUD but other conditions can and should be addressed.
In-person visits are sometimes required—CMS has required an in-person visit no more than six months before the telehealth visit, and at no greater than every 12 months after. However, the 12-month periodic in-person visit can be waived if a provider documents that the burdens of an in-person visit outweigh the benefits; and how vital signs, patient monitoring data, and lab testing are available as needed. Finally, all in-person requirements can be waived for SUD telehealth visits.
Audio-visual technology preferred but audio-only allowed—CMS’ preference remains for audio-visual telehealth visits, but audio-only may be delivered if the patient does not have the capabilities or does not consent to participate in a video telehealth visit, and this is appropriately documented.
- Aronowitz SV, Engel-Rebitzer E, Dolan A, et al. Telehealth for opioid use disorder treatment in low-barrier clinic settings: An exploration of clinician and staff perspectives. Harm Reduct J. 2021 Nov 25;18:119.
- Olfson M. The rise of primary care physicians in the provision of US mental health care. J Health Polit Policy Law. 2016 Aug;41(4):559-83. doi: 10.1215/03616878-3620821. Epub 2016 Apr 28.
- Connolly SL, Gifford AL, Miller CJ, et al. Provider perceptions of virtual care during the Coronavirus Disease 2019 Pandemic: A multispecialty survey study. Med Care. 2021 Jul;59(7):646–52.
- Voils CI, Venne VL, Weidenbacher H, et al. Comparison of telephone and televideo modes for delivery of genetic counseling: A randomized trial. J Genet Couns. 2018 Apr;27(2):339–48.
- Samuels EA, Khatri UG, Snyder H, et al. Buprenorphine telehealth treatment initiation and follow-up during COVID-19. J Gen Intern Med. 022 Apr; 37(5): 1331–1333. Published online 2022 Jan 3. doi:10.1007/s11606-021-07249-8.
Clinical Practice, COVID-19, Health Policy & Advocacy, Medical Education, SGIM, Vulnerable Populations
Dr. Heiman (email@example.com) is an assistant professor at the Emory School of Medicine and a physician site lead for the Grady Primary Care Center. Dr. Suen (firstname.lastname@example.org) is a research and clinical fellow within the UCSF National Clinician Scholars Program. Dr. Wootten (email@example.com) is an assistant professor in the Department of Psychiatry and Behavioral Health at Emory University School of Medicine and the medical director of Grady Outpatient Behavioral Health Services. Dr. Goodson (firstname.lastname@example.org) is a physician at Massachusetts General Hospital and an associate professor at Harvard Medical School.
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