The proposed physician fee schedule would create five new services that FQHCs can bill for, including:
- Remote Physiologic Monitoring
- Remote Therapeutic Monitoring
- Community Health Integration
- SDOH Risk Assessment
- Principle Illness Navigation
The payments listed above would be separate from and in addition to Medicare per-visit PPS payments, and the last 3 services listed above could be billed by a community health worker. FQHCs could bill for each service once per patient per month, and reimbursement would be slightly lower than the amount they currently receive for care coordination.
The proposed rule also contains technical changes implementing the new law allowing FQHCs to receive Medicare PPS payment for services provided by Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs.) This law goes into effect on January 1, 2024.
Unfortunately, CMS did not propose a regulatory fix that would have permanently paid FQHCs their Medicare PPS for medical services provided via telehealth. (Last year CMS finalized a policy to allow for permanent PPS payment for behavioral health services provided via telehealth.) CHCANYS will be submitting comments on the proposed rule in coordination with NACHC.