top of page

Closing 2022 with New Telehealth G-Codes for HHAs, Uncertainty for Telehealth Startups, Plus State & Federal Telehealth Developments (and much more!)


December 13, 2022

New G-Code Reporting Requirements for HHAs under CY 2023 CMS PPS Rule

The Centers for Medicare and Medicaid Services (CMS) has finalized new G-codes to report use of telecommunications technology under the home health benefit for Home Health Agencies (HHAs) under their finalized Calendar Year (CY) 2023 Home Health Prospective Payment System (PPS) Rate Update. HHAs are asked to voluntarily start reporting on January 1, 2023, and the requirement to report would kick in July 2023. CMS notes that in 2020 the home health benefit was temporarily altered due to COVID-19 (and made permanent in 2021) requiring any provision of remote patient monitoring or other services furnished via a telecommunications system to be included in the plan of care. The telecommunication service, however is not allowed to substitute for a home visit ordered by the plan of care or for purposes of eligibility or payment. Reporting of the new G-codes will allow CMS to analyze the characteristics of beneficiaries utilizing services remotely and have a broader understanding of the social determinants that affect who benefits most from these services. The codes HHAs will be asked to submit are detailed in a Medicare Learning Network (MLN) document, and include:
G0320: Home health services furnished using synchronous telemedicine rendered via a real-time two-way audio and video telecommunications system
G0321: Home health services furnished using synchronous telemedicine rendered via telephone or other real-time interactive audio-only telecommunications system
G0322: The collection of physiologic data digitally stored and/or transmitted by the patient to the home health agency (for example, remote patient monitoring)
For more details on the G-codes and reporting expectations, see the full MLN Guidance and the full text of the finalized CY 2023 Home Health PPS Rate Rule.

Falling Investment for Telehealth Startups

A recent article in Politico [subscription required] brings to light the stark decrease in investment in telehealth companies in 2022 (compared to 2021), as the pandemic subsides and a recession likely kicks in. In fact, while telehealth funding for digital health in the US peaked in 2021 with $11 billion dollars, that has fallen to only $3 billion by the third quarter of 2022. The effects of this slow down in capital is bound to ripple across the industry. As a result, many startups are laying off workers and focusing on just a few key offerings. Adding to the uncertainty of the future for these companies is how telehealth policies will impact them moving forward as state and federal governments shift from pandemic era temporary policies to often stricter permanent telehealth requirements with greater oversight. Cerebral, a digital mental health company, for example is currently under federal investigation for over-prescribing ADHD medication. This is the type of occurrence other telehealth companies may take note of and may shape the way they think about the future of their products and services in order to avoid such situations. Additionally, consumer demand has shifted post-pandemic. While consumers were enthusiastic about utilizing telehealth for most forms of healthcare in order to avoid crowded doctors’ offices and hospitals at the height of the pandemic, they now prefer to use it for check-ins with their doctors, mental health visits and addiction treatment, according a survey by the American Medical Association. This necessitates a shift for many telehealth start-ups, and according to Megan Zweig, COO of Rock Health, many companies are struggling with this. For more information, read the full Politico article [subscription required].

World Health Organization Telemedicine Implementation Guidance

In November the World Health Organization (WHO) released a telemedicine implementation guide based on knowledge and learnings the WHO has gathered since releasing their first report on telemedicine in 2010. The set of recommendations within the new guide is aimed at optimizing the implementation of telemedicine services by providing an overview of key planning, implementation and maintenance processes to inform an investment plan and support countries across different stages in developing telehealth solutions. The guide contains three phases to developing a successful telehealth program, including (1) a situational assessment; (2) planning the implementation; and (3) monitoring and evaluation, and continuous improvement. There are a total of eleven steps within the three phases, including tasks such as performing a landscape analysis, establishing standard operating procedures, developing a budget and determining monitoring and evaluation goals, as well as an adaptive management plan for improvement. Several case studies from different countries, including India, Cabo Verde, Indonesia, Qatar and Mali are also provided in the annex section of the document. Download the full telemedicine implementation document from the WHO’s website for all the detailed steps outlined in their recommended procedures for telemedicine implementation.

See full article:

bottom of page