CMS Resources: Telehealth Services Post COVID-19
Update 05/10/2023
We have received the following update from CMS confirming that DSMT may continue to be furnished via telehealth in all care settings, including HOPD.
21. [UPDATED] Following the end of the PHE, can hospitals bill for outpatient physical therapy (PT), occupational therapy (OT), speech language pathology (SLP) services, Diabetes Self-Management Training (DSMT), or Medical Nutrition Therapy (MNT) provided to beneficiaries in their homes through telecommunication technology by hospital-employed staff? In context of the end of the PHE, we have received a number of inquiries from interested parties regarding the expiration of this policy. We have reviewed all of the relevant guidance, including applicable billing instructions and external feedback, and recognize the confusion around these policies. We also recognize that the therapists and many of the other practitioners who provide these services remain on the list of distant site practitioners for Medicare telehealth services. However, for DSMT services, we understand that some other types of hospital clinical staff, beyond those identified as eligible distant site practitioners for Medicare telehealth, can provide these services in some cases. To allow these services to continue to be furnished to patients in their home through telecommunication technology through the end of CY 2023, we are exercising enforcement discretion in reviewing the telehealth practitioner status of the clinical staff personally providing any part of a remotely furnished DSMT service, so long as the practitioner is otherwise qualified to provide the service. Through the end of CY 2023, PT, OT, SLP, DSMT, MNT providers should continue to bill for these services when furnished remotely in the same way they have been during the PHE.
DSMT SERVICES MAY CONTINUE TO BE PROVIDED VIA TELEHEALTH.
Questions have been raised if DSMT services provided from programs located in a Hospital Outpatient Department (HOPD) are reimbursable when delivered via telehealth. Since there have been conflicting responses from CMS staff and in their guidance FAQs about DSMT reimbursement via telehealth, specifically in HOPD setting, we are requesting written guidance related to this issue.
In the meantime:
- DSMT telehealth reimbursement remains the same as during the PHE for most practice settings. Programs billing from an HOPD (using the UB-04 form) is the setting in which telehealth coverage is in question.
- ADCES Accredited and ADA Recognized programs were added to the list of approved telehealth providers via the 1135 Waivers. H.R.2471 - Consolidated Appropriations Act, 2022 extending the public health emergency flexibilities that have allowed DSMES programs to furnish services via telehealth and receive reimbursement for DSMT through the end of 2024.
- DSMT is paid on the Physician Fee Schedule (PFS), not the Outpatient Prospective Payment System (OPPS). DSMT is billed to Medicare part B as a professional service. When billing DSMT in the HOPD setting, the facility fee does not apply. In the HOPD setting, DSMT is still paid via PFS. DSMT HCPCS codes G0108 and G0109 are found on their Lookup Tool.
- DSMT has been on the Medicare Telehealth list of services paid on the PFS prior to and during the PHE and remains on that list today.
- According to the most recent End of PHE FAQ from CMS: per “the Consolidated Appropriations Act, 2023, eligible distant site physicians and practitioners may still be able to bill as a Medicare telehealth service under the Medicare physician fee schedule for professional services furnished via telehealth to individuals in their homes through December 31, 2024.” (LINK TO FAQ)
- When billing for telehealth, use modifier 95 to indicate the service was provided via telehealth. Medicare has stated that practitioners can continue to report the place of service code that would have been reported had the service been furnished in-person. Medicare has NOT identified place of service modifier 10 for use when the patient is in their home at this time. Here is a link to Medicare’s place of service codes.
Remember the basics of DSMT Benefit still apply:
- Individual DSMT encounters are reimbursable for the initial 10 hours, if special needs/barriers that would hinder effective participation in a group session are identified on the referral order, such as:
- Medical need: Vision, hearing, language, cognition limitations, etc.
- Non-ambulatory
- Additional insulin training is ordered
- No group session available within 2 months of the referral date
National experts at the American Diabetes Association, the Association of Diabetes Care and Education Specialists and the Academy of Nutrition & Dietetics are continuing to work together and will provide updates as more information becomes available.