Michael A. Cassidy

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Medicare Proposed 2025 Telehealth Changes

Michael A. Cassidy, Esq., (412) 594-5515, mcassidy@tuckerlaw.com

CMS (Centers for Medicare & Medicaid Services) proposed several telehealth changes in the 2025 Medicare Physician Fee Schedule Proposed Rule, issued July 10, 2024.

Interactive Telecommunication

Beginning January 1, 2025, an interactive telecommunication system may include two-way, real-time audio-only communication technology for any telehealth service furnished to a beneficiary in their home, if the distant site physician or practitioner is technically capable of using an interactive telecommunication system but the patient is not capable of, or does not consent to, the use of video technology.

Distant Site Address

CMS will continue to permit the distant site practitioner to use their currently enrolled practice location instead of their home address when providing telehealth services from their home.

Direct Supervision

CMS is proposing to adopt, for a certain subset of services that are required to be furnished under direct supervision of a physician or other supervising practitioner, to permanently adopt the definition of direct supervision that allows the physician or supervising practitioner to provide such supervision through real-time audio and visual interactive telecommunications. CMS is specifically proposing that the physician or supervising practitioner may provide such virtual direct supervision for services furnished incident to a physician service when they are provided by auxiliary personnel employed by the physician and working under his or her direct supervision.

CMS has also proposed that “immediate availability” for purposes of direct supervision for all other services will include real-time audio and visual interactive communications only through December 31, 2025.

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July 15, 2024