Billing Telehealth Updates for the South Central Region – October 2021

The Arkansas, Tennessee, and Mississippi Virtual Visit Billing Guides have been updated with significant telehealth policy changes!  Numerous payor policy changes occurred in the October, as the COVID-19 Federal Public Health Emergency (PHE) was renewed for another 90 days, now set to expire January 15, 2022.

CMS did make a significant change by adding a new place of service code effective January 1^st, 2022, which is POS 10 “Telehealth Provided in Patient’s Home”.  CMS also renamed the original telehealth place of service (02), to “Telehealth Provided Other than in Patient’s Home”.  Medicare does not currently have a use for this code, as Medicare has not permanently waived the originating site requirement.  However, the addition of the new place of service code provides a sign that Medicare will potentially remove the originating site restriction permanently.

Arkansas Medicaid’s COVID-19 telehealth flexibilities are set to end December 31^st, 2021, which includes the originating site requirement waiver.  If AR Medicaid’s flexibilities do expire, then telehealth would no longer be allowed when the patient is located at home. We will be monitoring closely for extensions.

Below are the detailed updates:

CMS

• Effective January 1^st, 2022, CMS added a new POS and renamed the original telehealth POS
  • POS 02:
    • Old Name: “Telehealth”
    • New Name: “Telehealth Provided Other than in Patient’s Home”
  • POS 10-NEW: “Telehealth Provided in Patient’s Home”
• Medicare has not identified a need for POS 10, therefore providers should continue to utilize POS 02 until further notice.

CIGNA

• Extended member cost share waiver for diagnostic testing and office visits/telehealth visits related to assessment and administration of diagnostic testing through January 15^th, 2022
• Directed providers to now use POS 02 for all virtual services.

MEDICA

• Extended current telehealth flexibilities and cost share waiver for in-network telehealth visits when related to administration of a COVID-19 test through January 31^st, 2021.

MEDICAID

• Arkansas:
  • All of AR Medicaid’s COVID-19 telehealth flexibilities are set to end December 31^st, 2021, including:
    • Originating Site Requirement Waiver
    • Professional Relationship Waiver
    • Parental Consultation Telehealth
    • Individual Therapy Services Telehealth
    • Applied Behavioral Analysis (ABA) Telehealth
    • Virtual Check-Ins (G2012) Telehealth
    • Behavioral Health Telehealth
  • Will continue to monitor to see if certain flexibilities will be extended, particularly the originating site requirement waiver, which allows telehealth to be provided when the patient is at home.