Back in November, APA posted considerations for practices to start making preparation for the potential ending of the telehealth flexibilities under Medicare. Specifically, the requirement for Medicare beneficiaries to have an in-person visit within 6-months of their telemental health appointment. This requirement has never been implemented due to the COVID-19 Public Health Emergency, as well as advocacy efforts by APA and others, to delay or permanently remove this law.

Without further congressional action this flexibility is set to expire again on March 31. This potential threat again marks a significant shift in the landscape of telemedicine. Telemedicine is a bipartisan issue, and there are active conversations happening on the hill to extend these vital flexibilities. However, until these flexibilities are officially extended, we are encouraging psychiatrists to consider taking the following steps:

Practice Considerations

• Start your planning process early.
  • There may be additional needs for patients with co-occurring medical or surgical conditions who would be at increased risk for poor outcomes.
• Review your current patient list to identify those who may be affected by this change.
  • Collaborate with primary care physicians in your patient's local area.
  • Psychiatrists may need to be in direct contact with a patient’s specialty provider (i.e., oncologist, rheumatologist, etc.) rather than their PCP if the psychiatrist is providing psychiatric consultation or care for a patient requiring specialty service.
  • The APA Find a Psychiatrist provides a way to search by zip code, city, and state to help find a psychiatrist in the local area.
  • Provide patients with information about local support groups and peer support services.
• Consider adjustments to scheduling and staffing to accommodate more in-person appointments.
• Develop a communication plan to inform patients about the potential changes and discuss their options.
• Update telehealth and in-person policies, protocols, procedures, and safety measures to align with the new requirements.
  • Review the APA such as the Telepsychiatry Toolkit & the Resource Document on Best Practices in Sychronous Videoconferencing-Based Telemental Health
• Ensure that all telehealth sessions are documented accurately and comply with any existing regulations.
• Stay up-to-date on payer policies as some may change coverage for telehealth services.
  • Center for Connected Health provides a guide on Medicare billing (.pdf).

The time to plan and communicate is now! You can also get involved in APAs advocacy on this issue and others that impact psychiatry by signing up for Advocacy Alerts.