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Telehealth and Coronavirus

Friday, March 13, 2020   (0 Comments)
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With the community-spread of COVID-19, many patients may be unable or unwilling to travel to their psychiatrist’s office to keep their appointments. Additionally, psychiatrists situated in hospital or other critical care settings may wish to transfer their in-person patient caseload to something virtual in order to protect patients. With recent legislation at both the federal and state levels, this is becoming more feasible with respect to laws, regulations, and reimbursement policies around telemedicine.


Last week, the President signed into law the Coronavirus Preparedness and Response Supplemental Appropriations Act. This statute gives the Secretary of Health and Human Services (HHS) the authority to waive both of these Medicare telehealth reimbursement restrictions for mental health services overall, during certain emergency periods. However, there are two stipulations:

  • In order to be eligible for telehealth encounter while located in (“seen”) in the home, the patient must have been seen by the provider (e.g., billed to Medicare) within the last three years, up to the date of the initial telehealth encounter.
  • If the patient intends to see a new provider for a telehealth encounter, the patient must have been seen by a provider from the same medical practice, operating under the same Tax Identification Number (TIN), within the last three years.

Please note: That while the legislation above grants the HHS Secretary the authority to make these changes, Secretary Azar has not yet announced whether or when it plans to do so. We are notifying you of these possible changes so that you can prepare.  APA is monitoring the situation and will keep its members notified of any progress.


Also, many governors are announcing states of emergencies in their respective states and are waiving similar originating site restrictions for Medicaid participants, allowing for patients to be seen in the home. It is a good idea to contact your state Board of Medicine, or Medicaid administrator, to see if these have been lifted for your Medicaid patients. Further, states where an emergency declaration have been made are eligible to have telehealth geographic site restrictions lifted for Medicare Advantage members enrolled in Part B, allowing patients to be seen in the home. For more information, see this “special requirements” memorandum from CMS. Note that this memorandum also includes guidance around Medicare Part D.


Finally, some private insurers are also lifting similar restrictions imposed on patients. If you accept private insurance, some of these carriers are mailing letters to providers, informing them of this change; if you have not yet heard from them, it would be a good idea for you—or your patient—to contact them in order to clarify whether such restrictions exist.


We have developed a sample letter for you to send to the private insurers and Medicaid agencies to inquire about altering restrictions and paying for needed billing codes.  It can be found on APA’s Telepsychiatry Blog on COVID-19 practice considerations here. More information on Medicare telehealth requirements, as well as billable CPT codes, can be found here.


For more information about how to provide care for your patients through telepsychiatry in response to COVID-19, click here


I ask that you share this information with your colleagues.  If you have additional questions, please contact the Practice Management Help Line.

Saul Levin, MD, MPA, FRCP-E, FRCPsych

CEO & Medical Director

American Psychiatric Association

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