CMS Publishes Sweeping Policy Changes in Interim Final Rule

Updates and regulatory changes continue to pour in as the COVID-19 crisis continues.  Yesterday, CMS issued an Interim Final Rule (IFC) with sweeping changes for telehealth services effective March 1, 2020.

The main highlights include:

  • Telephone services (for audio only) are now covered under CPT codes 99441-99443 and 98966-98968. 
  • Office outpatient visits furnished via telehealth may be coded based upon time or medical decision making only.  Documentation requirements for history and physical exam have been removed for office outpatient visits only.
  • Direct supervision for incident-to services may now be provided remotely via real-time audio and video telecommunications technology.  
  • Direct supervision for most resident services by a teaching physician may now be provided remotely via real-time audio and video telecommunications technology.  
  • The place of service (POS) requirements have been updated to indicate that providers should report the POS that would have been reported if the service had been furnished in person.
  • Modifier 95 should be reported with all telehealth services.
  • 80 additional telehealth services have been added, such as:
    • Critical Care Services
    • Emergency Department Services
    • Initial hospital Care and Hospital Discharge Day Management
  • There are MANY other changes which affect home health, hospice, ambulance, and rehabilitation providers.

We recommend referring to the CMS and other regulatory sites frequently as changes and updates are occurring rapidly.  CMS has a dedicated page on their website for all emergency updates here:

HBE is available to assist with the training of your providers and staff on the wide range of changes and can also provide assistance with policy revisions, auditing and other compliance needs you may have.  We will continue to monitor these important developments.

HBE is also offering a FREE webinar April 2, 2020 to discuss all of the telehealth and virtual service changes and updates.  To register, please go to:

The IFC can be found here:

The announcement can be found here:

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