CMS's Second Interim Final Rule Further Expands Telemedicine, Service Availability and Payment Flexibilities Related to the COVID-19 Pandemic

Baker Ober Health Law

CMS recently issued its second round of changes to the Medicare regulations in response to the COVID-19 Public Health Emergency (PHE). CMS published its first interim final rule with comment period addressing the PHE in the April 6, 2020 Federal Register, effective March 31, 2020 (March 31 IFC). 

In this more recent interim final rule with comment period (IFC), the Secretary once again has made broad and substantial temporary changes to the Medicare rules to promote greater access to health care, protect patients and practitioners from infection, and provide for financial relief to providers, suppliers and practitioners. The rules implement the Secretary's efforts as well as implementing provisions of recent laws passed by Congress related to the PHE. 

While the rules are effective on May 8, 2020, the policies are applicable beginning on March 1, 2020, or January 27, 2020, except as further detailed in the Federal Register for certain provisions. Comments are due by July 7, 2020.

To enable providers and suppliers to navigate this complex set of changes, we have developed this Quick Reference Chart for the interim final rule. Please note this is a summary and readers interested in particular provisions should consult the rules directly for the details.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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