Allison Cohen on Telehealth

CMS Proposes Extending COVID-Era Telehealth and Supervision Flexibilities through CY 2025

The Centers for Medicare & Medicaid Services (CMS) proposed to extend a number of COVID-era regulatory flexibilities related to telehealth, remote services, and supervision in the CY 2025 Medicare Physician Fee Schedule (PFS)...more

7/30/2024 / Centers for Medicare & Medicaid Services (CMS) , Coronavirus/COVID-19 , Health Care Providers , Healthcare , Medicare , Mental Health , Physician Fee Schedule , Physicians , Proposed Rules , Substance Abuse , Telehealth , Telemedicine

2024 Medicare Physician Fee Schedule Final Rule Extends COVID-19 Telehealth Policies and Includes Bonus Extension

The CY 2024 Medicare Physician Fee Schedule Final Rule (Final Rule) implemented several statutory extensions to COVID-19 telehealth waivers and flexibilities, finalized proposed policies, and extended an important telehealth...more

11/15/2023 / Centers for Medicare & Medicaid Services (CMS) , Consolidated Appropriations Act (CAA) , Health Care Providers , Hospitals , Medicare , Physician Fee Schedule , Physicians , Reimbursements , Telehealth

DEA and HHS Extend Telemedicine Flexibilities for Controlled Substance Prescriptions Through 2024

On October 6, 2023, the Drug Enforcement Agency (DEA) and the Department of Health and Human Services (HHS) announced they would further extend the COVID-19 flexibilities allowing for telemedicine prescription of controlled...more

10/16/2023 / Controlled Substances , DEA , Department of Health and Human Services (HHS) , Health Care Providers , Prescription Drugs , Telehealth , Telemedicine

Significant 2024 Medicare Physician Fee Schedule Rule Proposals: E/M, Social Determinants of Health, and Behavioral Health

In this article, we highlight a number of policy proposals in the current year (CY) 2024 Medicare Physician Fee Schedule (MPFS) Proposed Rule that have significant health care delivery and operational implications. These...more

8/14/2023 / Centers for Medicare & Medicaid Services (CMS) , Health Care Providers , Medicare , Physician Fee Schedule , Physicians , Proposed Rules , Risk Assessment , Telehealth

CY 2024 Medicare Physician Fee Schedule: Extending Telehealth Flexibilities and Seeking Future Policy Input

CMS recently released the CY 2024 Medicare Physician Fee Schedule (MPFS) Proposed Rule (Proposed Rule), which included many noteworthy proposals and clarifications related to Medicare telehealth services and other remote...more

7/24/2023 / Centers for Medicare & Medicaid Services (CMS) , Consolidated Appropriations Act (CAA) , Health Care Providers , Medicare , Physician Fee Schedule , Physicians , Telehealth , Telemedicine

Making Sense of the Varying End Dates of Telehealth Waivers and Flexibilities When the PHE Ends on May 11th

With the COVID-19 Public Health Emergency (PHE) ending on May 11th, providers and practitioners must carefully consider the dates when various telehealth waivers and flexibilities end. This requires understanding the...more

5/10/2023 / Health Care Providers , Home Health Care , Hospitals , Medicare , Physician Fee Schedule , Public Health Emergency , SAMHSA , Telehealth , Waivers

While the Public Health Emergency (PHE) is Projected to End May 11, Medicare Telehealth Coverage Expansions Were Extended Through...

President Biden recently announced that his administration plans to end the COVID-19 PHE on May 11, 2023. This provides more clarity about the long-anticipated end date for certain telehealth waivers and enforcement...more

2/14/2023 / Centers for Medicare & Medicaid Services (CMS) , Coronavirus/COVID-19 , Department of Health and Human Services (HHS) , Health Care Providers , Medicare , Public Health Emergency , Telehealth , Telemedicine

Public Health Emergency Declaration Again Extended; Key Flexibilities Decoupled

On January 11, 2023, Department of Health and Human Services (HHS) Secretary Xavier Becerra again renewed the declaration of a Public Health Emergency (PHE) under the Public Health Service Act, extending the declaration...more

1/19/2023 / Centers for Medicare & Medicaid Services (CMS) , Coronavirus/COVID-19 , Health Care Providers , Medicaid , Public Health Emergency , Telehealth

Noteworthy Telehealth and Remote Services Provisions in the CY 2023 Medicare PFS Final Rule

On November 1, 2022, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2023 Medicare Physician Fee Schedule (PFS) Final Rule. This article highlights noteworthy provisions of the Final Rule...more

11/21/2022 / Centers for Medicare & Medicaid Services (CMS) , Final Rules , Health Care Providers , Medicare , Physician Fee Schedule , Telehealth , Telemedicine

Safeguarding Against Discrimination in Telehealth to Meet Requirements of New Federal Guidance and the Proposed Rule Implementing...

With telehealth becoming increasingly prevalent, the federal government has taken steps to protect against discrimination in telehealth and prevent accessibility issues that disproportionately affect individuals with...more

8/31/2022 / Affordable Care Act , Department of Health and Human Services (HHS) , Disability Discrimination , Health Care Providers , Reasonable Accommodation , Section 1557 , Telehealth , Telemedicine

Key Telehealth Proposals in Calendar Year 2023 Medicare Physician Fee Schedule Proposed Rule

On July 29, 2022, the Calendar Year (CY) 2023 Medicare Physician Fee Schedule (PFS) proposed rule was published in the Federal Register. The proposed rule includes several noteworthy proposals related to telehealth and other...more

8/5/2022 / Centers for Medicare & Medicaid Services (CMS) , Health Care Providers , Medicare , Physician Fee Schedule , Telehealth , Telemedicine

Telehealth Flexibilities Get Another Shot through a Temporary Extension under the Omnibus Spending Bill

On March 15, 2022, President Biden signed the Consolidated Appropriations Act, 2022, an omnibus bill which includes, among other spending measures, a five-month extension of regulatory flexibilities that have allowed for...more

3/29/2022 / CARES Act , Centers for Medicare & Medicaid Services (CMS) , Consolidated Appropriations Act (CAA) , Coronavirus/COVID-19 , Health Care Providers , Telehealth , Time Extensions

Key Telehealth Provisions in the Calendar Year 2022 Physician Fee Schedule Final Rule

On November 2, 2021, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2022 Medicare Physician Fee Schedule (PFS) final rule (Final Rule), which finalized several noteworthy policies related...more

11/11/2021 / Centers for Medicare & Medicaid Services (CMS) , Final Rules , Health Care Providers , Medicare , Physician Fee Schedule , Physicians , Telehealth

OIG Reports Highlight State Challenges and Call for Increased Oversight to Improve the Provision of Medicaid Behavioral Health...

The U.S. Department of Health and Human Services Office of Inspector General (OIG) recently issued two data briefs addressing challenges with the provision of behavioral health services to Medicaid enrollees, and calling for...more

10/5/2021 / Centers for Medicare & Medicaid Services (CMS) , Coronavirus/COVID-19 , Medicaid , OIG , Regulatory Oversight , Telehealth

Telehealth, Split or (Shared) Visit, Critical Care, and Teaching Physician Billing Proposals in the CY 2022 Medicare Physician Fee...

On July 13, 2021, CMS released the Calendar Year (CY) 2022 Medicare Physician Fee Schedule (PFS) proposed rule, which includes several noteworthy proposals related to telehealth, billing for split (or shared) visits, critical...more

7/29/2021 / Health Care Providers , Medicare , Physician Fee Schedule , Physicians , Reimbursements , Telehealth , Telemedicine

The FCC's COVID-19 Telehealth Program Round 2 Application Window is About to Open for a Narrow One-Week Timeframe

The Federal Communications Commission (FCC) announced that it will accept applications for Round 2 of the COVID-19 Telehealth Program (the Program) from 12:00 p.m. ET Thursday, April 29 to 12:00 p.m. ET Thursday, May 6, 2021....more

4/29/2021 / CARES Act , Consolidated Appropriations Act (CAA) , Coronavirus/COVID-19 , FCC , Health Care Providers , Telehealth , Telemedicine

A Deeper Dive into Telehealth, Graduate Medical Education and Rural Health Care Provisions in the Stimulus Legislation

In addition to the key health care provisions included in the Consolidated Appropriations Act of 2021 (Stimulus Legislation) summarized in Baker Donelson's recent publication, the new legislation includes a few additional...more

1/19/2021 / Consolidated Appropriations Act (CAA) , Graduate Medical Education , Health Care Providers , Hospitals , Medicare , Public Health Emergency , Reimbursements , Rural Health Care Providers , Telehealth

CMS Continues to Support Telehealth and Virtual Care Policies in the CY 2021 Medicare Physician Fee Schedule Final Rule

On December 1, 2020, CMS released the Calendar Year (CY) 2021 Medicare Physician Fee Schedule (MPFS) Final Rule (Final Rule), which includes several policies to extend or make permanent certain policies to support expanded...more

12/7/2020 / Centers for Medicare & Medicaid Services (CMS) , Coronavirus/COVID-19 , Final Rules , Health Care Providers , Health Technology , Medicare , Physician Fee Schedule , Physicians , Public Health Emergency , Reimbursements , Telehealth , Telemedicine

CMS Announces Further Telehealth Expansions

On October 14, CMS announced several changes designed to expand access to telehealth. CMS made further additions to the list of services that Medicare will pay for practitioners to furnish through telehealth for the duration...more

10/20/2020 / Centers for Medicare & Medicaid Services (CMS) , Children's Health Insurance Program (CHIP) , Coronavirus/COVID-19 , Medicare , Public Health Emergency , Telehealth

Allison Cohen

Baker Donelson

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