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What are the post PHE changes, that Medical Practices and Medical Billers, are required to track?

Following months mark the emergence of the COVID pandemic which was announced back in 2020.

CMS announced a bunch of flexibilities and waivers to help with the challenges manifested during COVID era. After continued renewals and extensions in the whole course of PHE, looks like the final days of PHE brought by COVID-19 might be coming near to an end.

The last extension is recently revised again from October to December, adding another 90 days of PHE. There are many speculations that this might be the last extension.

Whatever the case maybe, its time we go through what we need to know about the waivers and flexibilities that were part of this whole course. As, most of these waivers and flexibilities are set to expire or at least go through some sort of transitions post-PHE.

Here are the main objectives:

  1. CMS also terminated waivers and flexibilities that were of importance at the beginning of PHE, CMS is assessing the need for continuing certain blanket waivers based on the current phase of the PHE.
  2. CMS is assessing which flexibilities would be most useful in a future PHE.
  3. CMS is continuing to collaborate with federal partners and the health care industry to ensure that the health care system is holistically prepared for addressing future emergencies.

Here are the few highlights:

Telehealth Coverage and services will remain intact, at least for a good while i.e.,151 days (only 5 months) after the PHE is declared concluded. The face-to-face encounter can be conducted via telehealth irrespective of the COVID-19 PHE; however, the waiver will expire the first day after the 151st day following the end of the PHE.

Evaluation and Management Visits via Telehealth:

CMS is resuming “frequency-limitations” on some specific E/M services conducted via telehealth during PHE. During PHE clinical staff assessing and collecting specimens for COVID using level 1 E/M shall also resume to its original requirements.

Behavioral and Preventive care Visits via Telehealth:

CMS has been allowing many behavioral health and education services to be furnished via telehealth using audio-only communications. Future of telehealth will be exciting nonetheless. As, PHE ends with this year, there is a probability a significant part of ‘telehealth/telemedicine’ might still live on.

MIPS changes:

Individual MIPS eligible clinicians who did not submit any MIPS data by the deadline of March 31, 2022 will automatically have all four MIPS performance categories reweighted to 0%. They will receive a neutral payment adjustment in the 2023 payment year. (This automatic policy does not apply to groups, virtual groups, or Advanced Payment Model Entities)

Referrals and Stark Law:

According to OIG, the Stark Law “prohibits physicians from referring patients to receive ‘designated health services’ payable by Medicare or Medicaid from entities with which the physician or an immediate family member has a financial relationship, unless an exception applies”. Waivers related to making referrals will be resume to comply with original Stark Law. When the PHE ends, the waivers will terminate and physicians and entities must immediately comply with all provisions of the Stark Law.

DMEPOS Billing:

CMS has been waiving signature and proof of delivery requirements for Part B drugs and Durable Medical Equipment (DME) after the PHE, signature and proof of delivery requirements will be reinstated as the PHE ends.

Vaccination Administration Billing:

Effective January 1 of the year following the year that the PHE ends, CMS will set the payment rate for administering COVID-19 vaccines to align with the payment rate for administering other Part B preventive vaccines. CMS will continue to pay approximately $40 per dose for administering COVID-19 vaccines in outpatient settings and pay a total payment of approximately $75 per dose to administer COVID-19 vaccines in the home for certain Medicare patients through the end of the calendar year that the PHE ends.

After the PHE, in accordance with the CARES Act, this special price transparency requirement will terminate. Price transparency requirements under other laws and regulations will continue to apply.


During the PHE, CMS allowed practitioners to render telehealth services from their home without reporting their home address on their Medicare enrollment while continuing to bill from their currently enrolled location. When the PHE ends, practitioners will be required to resume reporting their home address on the Medicare enrollment.

In Conclusion:

Maintaining Compliance with these post pandemic changes can prove to be a challenge. Healthcare Providers and medical billers need to be on the look-out to state laws as well and be wary and acquiescent in every regard. Reassessment of the current business models and care delivery models might be required, as most of the practitioners have widely accustomed themselves as telehealth practitioners.

Being non-compliant to changes, might put some practitioners at risk of auditing and investigations. AltuMED can help keep you up with these challenges, that might come with these changes. Being thoroughly watchful of the new changes and updates, we help you stay compliant to these upcoming alignments.

AltuMED is a Healthcare Revenue Cycle Management technology and solutions company. Our technologically advanced Practice Management Software, PracticeFit optimizes the Medical Billing workflows for Medical Practices, Labs and Third-Party Medical Billing Companies helping them collect maximum revenue. Find out more.

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