CMS clarifies timeline for phasing out F2F telehealth allowances

Corrected guidance from the Centers for Medicare and Medicaid Services (CMS) may clear up confusion among home health and hospice providers regarding the continuing use of telehealth for face-to-face encounters between patient and physician.

Providers will have an additional 151 days beyond the last day of the COVID-19 Public Health Emergency (PHE) to continue relying on telehealth to meet F2F requirements.

"CMS has corrected some previously conflicting language in its guidance to show that it will follow provisions enacted by Congress and extend the F2F telehealth allowance beyond the PHE,” said Kim Skehan, SimiTree Director of Compliance, Regulatory and Quality.

Congress addressed the extension in the Consolidated Appropriations Act of 2022 (CAA 2022), Skehan said, voting to extend the waiver allowing use of telehealth for the home health and hospice F2F through the 151st day following the end of the PHE.

Confusing guidance

Many providers were confused Aug. 18, when CMS issued extensive materials with guidance related to the planned phaseout of many regulatory waivers, enforcement discretion and flexibilities granted during the COVID-19 PHE. Those documents said CMS would terminate waivers and flexibilities at the end of the PHE.

The National Association for Home Care & Hospice (NAHC) wrote to CMS officials requesting a guidance revision to align with legislative changes.

"CMS has now responded to that request, acknowledging that it will adhere to the legislative changes, and has changed the wording of guidance on phasing out waivers and flexibilities,” Skehan said.

Updates have been posted to the Home Health and Hospice Fact Sheets reflecting the 151-day extensions and may be found here.

PHE extension expires next month

The timing of the clarification could be significant, as the current extension of the nation’s PHE is set to expire in October.

At that time, U.S. Department of Health and Human Services Secretary Sec. Xavier Becerra will either grant another 90-day extension or bring to an end the PHE which has remained in place since March 2020.

SimiTree helps with compliance, telehealth

If your organization has compliance questions, or needs assistance with setting up an efficient telehealth program that ensures return on investment, SimiTree can help.

Our compliance team is made up of industry experts with experience across the healthcare spectrum and extensive regulatory expertise. We offer full compliance assessments, work with organizations to establish more effective compliance processes and assist with all other compliance needs.

Our clinical operations consultants work with agencies to set up efficient processes for peak performance and can show your organization how to achieve more effective use of telehealth.

Use the form below to reach out to us today so that we can make your organization stronger and healthier overall.

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