Dear RHC Community,
On July 13th, the Centers for Medicare and Medicaid Services (CMS) issued the CY 2022 Medicare Physician Fee Schedule Proposed Rule. This year’s rule includes several significant Rural Health Clinic (RHC) policy proposals in the 1,747-page document.
Notably, CMS proposes to re-define what constitutes an “RHC encounter” to allow RHCs to provide mental health services through telehealth beyond the end of the public health emergency. We are happy to see this proposal as it will allow RHCs to treat these mental health services as a normal visit. CMS also proposes how to establish clinic-specific upper payment limits for grandfathered RHCs which, of course, has major implications for all previously uncapped RHCs.
The National Association of Rural Health Clinics (NARHC) will be providing comments to CMS in the coming months, you are welcome to offer feedback to NARHC (contact info below) or submit your own comments directly to CMS here.
RHC Mental Health Services Via Telehealth
In the Consolidated Appropriations Act of 2021, Congress permanently extended Medicare telehealth coverage of mental health services beyond the public health emergency (PHE). This was a positive step towards making all Medicare covered services provided via telehealth permanent, but legislation will still be needed to permanently extend other telehealth services before the end of the PHE.
In order to ensure that RHCs are not left behind, CMS is proposing to redefine what constitutes a mental health visit “to ensure that they reflect contemporary medical practice.” This proposal is a very positive step forward and we were glad to see CMS think proactively about how to extend new payment policy to RHCs.
Revising the Definition of an RHC Mental Health Visit
Prior to the COVID-19 pandemic, RHCs were only allowed to serve as originating sites for telehealth visits. The CARES Act of 2020 first allowed RHCs to serve as distant sites for telehealth visits, but it also established a special payment mechanism for RHC distant site services. This special payment mechanism paid one rate based on the national average payment rates for comparable telehealth services which is why RHCs bill for telehealth visits using HCPCS code G2025 and always get reimbursed $99.45 (for CY 2021). This temporary authority expires at the end of the public health emergency (PHE) and NARHC is working hard to get this extended permanently for all telehealth services.
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