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Explaining CMS's New Telehealth Waiver

by Aledade

The Federal government has removed many barriers to the implementation of telehealth and we discuss those changes here. Please remember that state laws and regulations dictate who can perform telehealth encounters and the patient consent process and also impose some additional requirements for conducting telehealth encounters Just because Medicare or another payer will pay for a telehealth service does not mean that their billing requirements ensure compliance with state laws and regulations. State-specific guidance is forthcoming in the full Telehealth toolkit that will be issued later this week.


On March 17, 2020, CMS issued guidance on the telehealth waiver. Retroactive to March 6, 2020, qualified professionals (MD/DO/NP/PA/CNS) can bill telehealth anywhere in the country and no matter where the patient is, including if they are home. A full list of telehealth services is available here. This allows practices to replace office visits with video-enabled visits when the patient is at home, in the parking lot, or anywhere. This requires the use of “audio and video capabilities that are used for two-way, real-time interactive communication.”  Physicians cannot replace an office visit with just a phone call. CMS already covers “virtual check-ins” over the phone (G2012)and of course chronic care management services, which does not require a face-to-face visit. If you are providing telehealth out of state, please be aware that many states have restrictions that may not allow out of state telehealth.

We have received many inquiries as to whether or not the telemedicine legislation will also enable Rural Health Centers and Federally Qualified Health Centers to bill for services. This waiver applies to all qualified professionals regardless of where they work, so RHCs and FQHCs can utilize this new authority. CMS has issued frequently asked questions


Disclaimer: Aledade endeavors to provide the most recent, actionable information pertaining to the quickly evolving state of emergency around COVID-19. Aledade regularly reviews a variety of publicly available health sources and updates its materials accordingly. Because data, regulations, and official pronouncements around COVID-19 change so frequently, however, some information contained herein may become outdated before we get the chance to update it. For the very latest on COVID-19, please continue to use online resources from CDC, WHO, and your state or local public health departments.