Telehealth Payments for FQHCs: The Legal and Policy Landscape
For federally-qualified health centers (FQHCs), telehealth plays a growing role in addressing provider shortages and ensuring access for patients to critical behavioral health and primary care services. In the Medicare program, FQHCs are paid under a prospective payment system (PPS)—a bundled payment methodology where all covered services are paid for through a per-visit rate. FQHCs must provide a face-to-face visit in order to receive PPS payment. The fact that PPS visits cannot be furnished through telehealth has posed a challenge for FQHCs in implementing technology-based approaches to care for their Medicare population.
In recent years, however, the federal Centers for Medicare & Medicaid Services (CMS) has recognized the growing role of remote care in FQHCs by authorizing several new types of Medicare payments to FQHCs for care coordination and communication technology-based services that are not necessarily furnished face-to-face. Payment for these services is typically outside the PPS rate.
This webinar will review federal law and CMS policy relating to telehealth and other communication technology-based services in payment to FQHCs.
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SUSANNAH VANCE GOPALAN
Susannah is a Partner in the firm’s health law practice group where she focuses on health care litigation and regulatory counseling, with a focus on Medicaid and Medicare payment, financing, and compliance issues. Susannah brings regulatory expertise to bear when advising clients and pursuing litigation on their behalf. She has experience negotiating Medicaid waivers and managed care arrangements on behalf of providers, provider associations, and governmental entities. She represented a group of providers in reaching a settlement in major Medicaid litigation. [Full Bio]
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