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Tele-Mental Health
What are the tele-health policies for provision of behavioral health services to Medicare beneficiaries?
Medicare patients can receive telehealth services for behavioral health care in their homes in any part of the country. This includes most behavioral health services, such as counseling, psychotherapy, and psychiatric evaluations. The in-person visit requirements before a client may be eligible for tele-behavioral health care services is delayed through December 31, 2024.
Medicare beneficiaries can receive tele-mental services in both the Traditional Medicare program and Medicare Advantage plans, including audio-only behavioral health services.
There will more guidance issued in 2024 on how tele-mental health coverage will be addressed.
Sources: Consolidated Appropriations Act, 2023 (PDF), Consolidated Appropriations Act, 2022 (PDF), Consolidated Appropriations Act, 2021 (PDF)
Can a practitioner provide telehealth services only, or does the provider need an actual office practice address? Does CMS require a physical office location or can fully telehealth providers participate in the Medicare program?
It is possible to be a telehealth-only Medicare provider. However, you will need to include comments within your Medicare provider enrollment application that the practice location address you are listing is for administrative purposes only and that you are a telehealth-only provider.
I am licensed in multiple states and use teletherapy to provide services in American Sign Language to my clients. The new Medicare requirement states that there must be a face- to-face meeting annually. How is this addressed for long distance counseling?
There is an exception to the annual in-person visit requirement. You can read more about the exception on page 26 of CMS’s Medicare Learning Network booklet titled, “Medicare and Mental Health.” 42 CFR 405.2463(b)(3) says there must be an in-person visit 6 months before providing telehealth mental health services and there must be an in-person, non-telehealth service within 12 months of each mental health telehealth service unless the physician and patient agree the risks and burdens outweigh in-person visit benefits and it’s documented in the medical record.
If approved through enrollment process in one state, would a provider be able to provide services in more than one state? If a provider relocated to another state next year, how would this process work?
Pursuant to current Medicare sub-regulatory guidance, the provider must be enrolled in the state or states where they provide services, such as the provider’s office location and/or home location if they provide services from their homes. Current CMS guidance indicate that the provider need not enroll in each state where the beneficiary resides. However, CMS currently indicates that the provider must be licensed in both the states where they are delivering services (new office/home location) and also the state where the beneficiary is receiving the services. We recommend that providers stay up to date on CMS guidance as it emerges and also the final Medicare Physician Fee Schedule Rule expected to be released in November!
If a provider moves to a new state, he or she would need to get licensed there and also enroll in the location where they reside if that is the location from which they will deliver services.