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Telehealth

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The Centers for Medicare and Medicaid Services (CMS) published the calendar year (CY) 2023 Medicare Physician Fee Schedule (MPFS) in the Federal Register for November 18, 2022. Some of the key provisions contained in the final rule include (and are effective on January 1, 2023):

Medicare Telehealth Services

  • Addition of new HCPCS codes to the list of Medicare telehealth services on a Category 1 basis.
  • Implementation of the 151-day extensions of Medicare telehealth flexibilities, including allowing telehealth services to be provided in any geographic area and in any originating site setting.
  • Permission for physical therapists, occupational therapists, speech-language pathologists, and audiologists to provide telehealth services.
  • Listing of codes added to the telehealth services list are here.

Evaluation & Management (E&M) Visits

  • For CY 2023, CMS finalized changes for “Other E/M” visits that parallel the changes that were made in recent years for office/outpatient E/M visit coding and payment. Other E/M visits include hospital inpatient, hospital observation, emergency department, nursing facility, home services, residence services, and cognitive impairment assessment visits.

Behavioral Health

  • Proposal finalized to create a new HCPCS code (G0323) describing General Behavioral Health Integration performed by clinical psychologists or clinical social workers to account for monthly care integration where the mental health services provided are serving as the focal point of care integration.

Chronic Pain Management

  • Finalized a CY 2023 proposal to create two new G codes (G3002 and G3003) performed by physicians and other qualified health professionals describing monthly CPM for payment starting January 1, 2023.

Opioid Treatment Programs (OTPs)

  • CMS finalized the proposal to allow the OTP intake add-on code provided via 2-way, interactive, audio-video technology when billing for the initiation of treatment with buprenorphine using audio-video technology to start treatment with buprenorphine as authorized by the Drug Enforcement Administration (DEA) and Substance Abuse and Mental Health Services Administration (SAMHSA) at the time the service is provided.
  • CMS also finalized the proposal to permit the use of 2-way, interactive, audio-only technology to start treatment with buprenorphine in cases where audio-video technology isn’t available to the patient and all other applicable requirements are met.

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Photo by Markus Winkler from Pexels

Recognizing the continued movement toward integration of mental health (MH) and substance use disorder (SUD) treatment, and the opportunity to better support and serve its MH and SUD provider members, RCPA has created a Behavioral Health Division.

RCPA’s MH and SUD policy focus will now operate under the BH Division umbrella, where shared MH and SUD interests and initiatives (e.g., workforce, value-based purchasing, telehealth, criminal justice, ICWCs/CCBHCs) will now be managed and supported across the disciplines — while still maintaining existing MH- and SUD-specific committees, subcommittees, and work groups where those interests are specific to one of the two policy areas.

Jim Sharp and Jason Snyder will direct the new BH Division.

  • As Director of Mental Health Services, BH Division, Sharp, whose work to date has focused largely on children’s MH, will maintain his MH policy focus, including continuing to lead separate Children’s Mental Health and Adult Mental Health Committees, along with the other MH-specific committees and work groups already in place.
  • As Director of Substance Use Disorder Treatment Services, BH Division, Snyder will maintain his policy focus on SUD and the existing SUD-specific committees and work groups.
  • In addition, RCPA will no longer use the Drug and Alcohol title (or D&A acronym), replacing it with SUD.
  • Both directors will also collaborate in areas of shared interest, including legislative, regulatory, and policy initiatives as appropriate.

RCPA will be hiring a BH policy analyst to support the new division.

“The new BH Division has the opportunity to capitalize on synergies where they exist while still maintaining discipline-specific focus on MH and SUD,” said RCPA President/CEO Richard Edley. “Rather than taking anything away from our mental health and substance use disorder members, we are really enhancing their membership.

“As we look at where the behavioral health field continues to move, integration of mental health and substance use disorder is a hallmark of the advancing field. RCPA will better position itself to support its provider members’ needs by structuring a BH Division that recognizes this evolution.”

Contact Division Directors Jim Sharp or Jason Snyder with questions.

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This week, the Centers for Medicare & Medicaid Services (CMS) announced the Calendar Year 2023 Physician Fee Schedule (PFS) final rule. The final rule includes several National Council and RCPA recommended priorities. These are wins for mental health and substance use care organizations that will help expand access to care by strengthening the workforce.

RCPA recommends members review this 2023 Physicians Fee Schedule Final Rule Summary for impacts on your agencies practice and/or policies.

Key Highlights:

  • Telehealth Flexibility Extensions: CMS is extending telehealth flexibilities implemented under the Public Health Emergency (PHE) for a 151-day period after the expiration of the PHE.
  • CMS is allowing behavioral health clinicians to offer services incident to a Medicare practitioner under general (rather than direct) supervision.
  • Licensed professional counselors and marriage and family therapists are now able to bill incident to Medicare practitioner for their services.
  • Medicare will allow opioid treatment programs to use telehealth to initiate treatment with buprenorphine for patients with opioid use disorder, continuing the flexibilities under the Ryan Haight Act of 2008.
  • CMS is also clarifying that opioid treatment programs can bill for opioid use disorder treatment services provided through mobile units, such as vans, in accordance with Substance Abuse and Mental Health Services Administration (SAMHSA) and Drug Enforcement Administration (DEA) guidance.

The Final Rule, in alignment with the Consolidated Appropriations Act (CAA) of 2022, implements an extension of a number of flexibilities for a 151-day period after the expiration of the Public Health Emergency (PHE), which is set to expire on January 11, 2023.

In the event of further extensions of the federal PHE, we will communicate this info to members. Under the current timeframe for PHE continuation, states must be notified by November 11, 2022.

We thank our members and Steering Committees for their guidance, recommendations, and support through the review process. If you have any questions, please contact your respective RCPA Policy Director.

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Expanding telehealth services during the COVID-19 pandemic was crucial to provide quality mental health and substance use treatment services to clients.

Did your organization provide telehealth services? What services will you continue post-pandemic?

We want to hear about your experiences! The survey will take less than 10 minutes to complete and will assist RCPA in our State and Federal Telehealth advocacy efforts.

Take the Survey Today!

Please complete the brief survey by 11:59 pm ET on Wednesday, Oct. 26.

The National Council will use these survey findings as part of a larger effort to collect and share data with policymakers, payers, and the field at large to improve access to mental health and substance use treatment services nationwide.

If you have any questions, please contact RCPA Policy Director Jim Sharp.

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