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CMS Issues Summary of Physician Fee Schedule Policies During the Public Health Emergency (PHE)

The Centers for Medicare and Medicaid Services (CMS) has issued a Medicare Learning Network (MLN) article with an effective date of June 12, 2020. The article summarizes the policy changes impacting the Physician Fee Schedule during the time of this Public Health Emergency (PHE). During the early part of the PHE, numerous changes were made to reimbursement policies associated with telehealth and non-face-to-face services. The article addresses the cumulative changes that occurred over this period. Specifically, the following topics are addressed:

  • Expansion of telehealth services to include certain hospital-based services
  • Outlines the change in requirements for telehealth modalities
  • Expansion of virtual check-in services to new and established patients
  • Direct supervision requirements for services provided by clinical staff
  • Reimbursement of telephone services and expansion of codes to both new and established patients
  • Documentation, code selection and reimbursement of E/M services during the PHE
  • Changes to supervision requirements for diagnostic tests
  • Application of Teaching Physician requirements for residents and expansion of therapy services provided by students
  • Flexibilities for Opioid Treatment Programs to use interactive technology for counseling, therapy and assessments
  • Guidelines for ordering COVID-19 testing

​ The article can be accessed here.


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