Today’s topic of discussion is crucially important for both Home Health and Hospice, as we aim to clarify the impending end of the Public Health Emergency. We have mentioned the approaching end of this emergency on several occasions over the past few months, and now the time has finally come. It is worth noting that the Public Health Emergency will officially end on May 11, 2023, which is this week. As a result, many of the 1135 waivers that were put in place will be discontinued on the same day.  

In previous Monday Minutes, we highlighted the National Association for Home Care and Hospice’s issuance of several reports and hosting a webinar on the end of the Public Health Emergency. Additionally, State Home Care Associations have been releasing numerous memos related to this topic. It is imperative that you pay attention to all of these resources to stay up-to-date with the changes that you may need to implement promptly. 

The most significant clarification to be aware of today concerns telehealth services. While we have previously mentioned the extension of telehealth for Face-to-Face encounters until December 2024, there has been a recent change regarding HIPAA compliance requirements. We stated that telehealth services provided on or after May 12, 2023 must be conducted via a HIPAA compliant system. However, the Office of Civil Rights, which oversees HIPAA regulations, has granted an additional 90-day extension to agencies for transitioning to HIPAA-compliant software. This means that the HIPAA compliance software restriction will not go into effect until August 10, 2023. Thus, agencies can continue to use non-HIPAA compliant systems that were used during the Public Health Emergency for telehealth Face-to-Face encounters and some telehealth services provided by Home Health agencies.  

As a reminder, Hospices will not be permitted to offer telehealth visits other than Face-to-Face encounters from May 12, 2023 forward, as mentioned earlier. Additionally, for Home Health services delivered via telehealth from May 12, 2023 and beyond, agencies must report them on their claims using the correct G-codes, which we will provide details on in this Minute. Starting July 1, 2023, this reporting requirement becomes mandatory.  

There are three G-codes that agencies must use to report their telehealth services. The first one is for reporting audio and video telehealth services, the second for phone call telehealth services, and the third for remote patient monitoring. It is important to note that while these codes are mandatory for reporting on claims, they do not currently offer any additional reimbursement. Therefore, Home Health agencies should be vigilant about meeting this reporting requirement and should ensure that the cost of telehealth services is accurately reflected in their annual Medicare cost report. It is our hope that this data collection will eventually lead Medicare to reimburse for these telehealth services.  

It is crucial to review all waivers related to the end of the Public Health Emergency that will expire on May 11, 2023. The fact sheets can be found here for Home Care and Hospice. The memo from OCR can be found here for your reference. Please ensure that you review these resources to stay informed about the upcoming changes.  

If you need any help with your Home Care or Hospice, please contact Healthcare Provider Solutions. We are always here to help you.  

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