Can a resident in a teaching physician program that’s located in a Metropolitan Statistical Area continue to provide telehealth services when the teaching physician is physically present with the resident during the key portions of the service?
Originally, CMS indicated that effective 5/12/2023 (after the PHE expired) only teaching physicians in residency training sites located outside of an MSA may meet the presence for the key portion requirement through audio/video real-time communications technology. However, CMS has since clarified that information through the CMS Waivers, Flexibilities, and the End of the COVID-19 Public Health Emergency dated 5/19/2023 which now allows for this practice to continue for all teaching physician services through 12/31/2023. CMS has indicated in the 2024 Physician Fee Schedule Final Rule that this policy will remain in place through 12/31/2024. See MLN Matters® MM13452: Medicare Physician Fee Schedule Final Rule Summary: CY 2024