With the onset of COVID-19, telepsychiatry use has dramatically increased. Clearly, providers are finding it a viable solution for treating patients previously seen in office settings. In response, CMS recently eased several reimbursement requirements for the use of telepsychiatry.
COVID-19: Telepsychiatry – Videoconferencing
Effective March 17, 2020, CMS is allowing providers to see patients via live videoconferencing in the patient’s home. This eliminates the previous requirement for the patient to travel to a qualifying “originating site” for Medicare telehealth services.
CMS defines telemedicine as the “use of live videoconferencing to facilitate a patient encounter.” For Medicare and Medicaid reimbursement, this does not include telephone alone. An encounter must include live video and audio paired together.
During the COVID-19 National Emergency, CMS is also waiving HIPAA penalties for using non-HIPAA compliant videoconferencing software. As a result, providers can use platforms such as Skype, FaceTime, and Zoom to conduct video telehealth sessions.
CMS is also temporarily waiving requirements that out-of-state practitioners possess a license in the state where they are providing services when they already have a license in another state.
For coverage of CMS’ easing of Medicare reimbursement requirements, see the American Psychiatric Association Update on Telehealth Restrictions in Response to COVID-19
The APA also publishes a very useful Telepsychiatry Toolkit.
COVID-19: Telepsychiatry –Prescribing Controlled Substances
Similar to CMS, The Drug Enforcement Administration (DEA) is easing requirements for in-person examinations of new patients. Current regulations require a provider to conduct an initial, in-person examination of a patient before electronically prescribing a controlled substance. However, the DEA has suspended this requirement for the duration of the COVID-19 National Emergency. In addition, they’ve waived the requirement for the provider to have a DEA license in the state where the patient is located.
Joint Commission Telehealth Requirements
On a related note, TJC recently issued an FAQ on providing telehealth services during an emergency situation. They clarified that organizations do not need to delineate telehealth services as a distinct privilege. Thus, if a licensed independent practitioner is currently credentialed and privileged to provide a service and would now be providing that same service via a telehealth link, this would not require any additional credentialing or privileging.
Clearly, CMS, TJC, and other regulatory bodies are finding ways to support providers during this National Emergency and make it easier for them to continue to treat patients. That’s certainly a laudable goal and much appreciated by the behavioral healthcare industry.
Barrins & Associates Resources
For additional resources and information related to COVID-19, see our recent posts:
- COVID-19: Behavioral Healthcare Resources
- COVID-19: CMS surveys and Top Priority Areas
- COVID-19: Suicide Risk Monitoring
Above all, we send our deepest gratitude to those healthcare workers on the front line continuing to serve patients during this pandemic. Thank you for all that you do every day!