Telehealth is one of the biggest and brightest changes healthcare has seen in a long time. Sure, it’s not the most exciting advancement in science or technology, but neither was sliced bread.

But it’s here to stay.

And because of that, we have moved into a time where legislatures are working to keep up. Specifically, we are referring to the Centers for Medicare & Medicaid Services (CMS). On July 7th, 2022, they released their proposed rule for 2023.

This means these are just their ideas, but if history is any indication, many of these changes will be in the final ruling, which will be released later this year.

These changes cover everything from expanding remote therapeutic monitoring codes to allowing ACOs to jump on the patient monitoring train. And while all of the proposed ideas are important, a few stick out.

So, in this post, we will quickly review how we got here, explain the top Medicare fee schedule changes proposed, examine what the CMS missed, and how ALL of this could impact you and your practice.

A Quick History of the Fee Schedule

Everyone has to get paid, right? And in an industry as vast as healthcare, there needs to be an equally vast standard for how to do it, specifically for fees paid to doctors and other providers via Medicare.

The CMS does a lot, including:

• Establishing health and safety guidelines
• Instituting clinical and quality programs
• Reimbursing facilities for services they provide Medicare patients
• Governing care costs
• Penalizing underperforming providers
• Rewarding high-performing ones

Each year, CMS releases proposed changes that reflect the evolution of healthcare needs and services.

Overview of the 2023 Fee Schedule Changes

This year’s proposal includes:

• Expanded Remote Therapeutic Monitoring (RTM) Codes
• Extended telehealth waivers
• Updates to Shared Savings Programs
• New codes for chronic pain and CBT
• Payment rate adjustments

Expanding Remote Therapeutic Monitoring (RTM) Codes

RTM is defined as monitoring non-physiological data, such as therapy response and overall health. In contrast to traditional RPM, RTM expands care coordination to include various clinical staff.

New 2023 proposal: Four new HCPCS G-codes allow broader billing permissions, helping reduce physician burden and increase access.

Extended Telehealth Waivers & Flexibility

CMS proposes a 151-day extension of telehealth flexibilities post-PHE. This includes:

• Remote services in any location, including homes
• Audio-only services
• Expanded billing privileges for PTs, OTs, SLPs, and audiologists

Shared Savings Program Changes

CMS offers updates for ACOs, including:

• Longer onboarding timelines
• Adjusted performance benchmarks
• Greater support for high-risk patient groups

New Mental Health Billing Codes

• CBT setup and supply code added
• New behavioral health “incident-to” billing for LPCs and LCSWs
• Psychiatric diagnostics during initial behavioral health visits allowed

Chronic Pain Management Codes

Two new codes address chronic pain services under general supervision. These do not require incident-to billing.

Physician Payment Cuts

Conversion factor drops from $34.6062 to $33.0775. Some specialties, like cardiology, could see a 1% payment reduction.

CMS Missed RPM Clarification

Despite strong industry feedback, CMS did not revise the 16-Day Rule. Current RPM billing for codes 99453 and 99454 still requires:

• Only one billing per 30-day period
• Minimum of 16 days of readings
• One billing practitioner, regardless of number of devices

This is a barrier to new RPM programs—especially in early implementation phases.

Where We Go From Here

If RPM is to survive post-PHE, CMS must legislate permanent policies. We hope to see:

• Continued audio-only coverage
• Expanded practitioner eligibility
• Permanent home as a telehealth site
• More flexibility in billing requirements

Tellihealth Stands With Your Practice

At Tellihealth, we monitor Medicare changes and provide solutions through our accuRPM platform—so your practice stays compliant and efficient. Want support navigating Medicare billing?

Schedule a demo to learn more about how we help practices implement sustainable, scalable remote care programs.