Stakeholders will be glad to know that CMS continued the RTM conversation with stakeholders beyond last year’s 2022 Medicare Physician Fee Schedule Final Rule (the “2022 Rule”) and directly addressed many of our questions and concerns, including NGL’s recommendations to re-visit the overall code structure to better align RTM with Remote Physiologic Monitoring (“RPM”) and other care management services.

For the first time, the Drug Enforcement Agency (“DEA”) is becoming directly involved in the telepharmacy space, an industry that the DEA has not previously regulated aside from the loose application of its existing regulations governing online pharmacies. Find out what this means for your business and how you can submit comments to the DEA directly in this post.

On November 2, 2021, the Centers for Medicare and Medicaid Services (“CMS”) finalized the Medicare Physician Fee Schedule for Calendar Year 2022 (the “Final 2022 MPFS” or the “Final Rule”). As we noted in our July article discussing the Proposed 2022 MPFS, CMS made some significant proposed changes to allow for audio-only telehealth in some limited circumstances. In addition, the agency also proposed to enable remote “direct supervision,” which would allow practitioners to supervise clinical staff billing incident to their services as long as they could be available by audio/video communication as necessary.