RCD Telehealth F2F Information
Article provided by CMS – MLN Booklet dated April 2025
Palmetto had a webcast about Review Choice Demonstration (RCD) on October 1. During this webinar, Palmetto staff stated tat all SOCs dated on or after October 1, 2025 would require a Face-to-Face encounter that was conducted in person. The justification is that the authorization to provide a Face-to-Face encounter via telehealth expired September 30, 2025. While the expiration of this authorization from Congress to provide a Face-to-Face encounter via telehealth did indeed expire on September 30, 2025, what Palmetto staff failed to consider in this policy announcement is that the Face-to-Face encounter can be conducted up to 90 days prior to the actual start of care.
The Alliance contacted Palmetto to seek clarification. During this discussion the time frame permitted for the Face-to-Face encounter, 90 days prior to or 30 days after the SOC. The CMS publication, MLN 901705 – Telehealth & Remote Patient Monitoring, indicating that the September 30, 2025 telehealth extension applies based on the actual date the patient received the telehealth service.
Palmetto acknowledged the Alliance’s interpretation and agreed that Face-to-Face encounters occurring within the permitted timeframes-including those performed up to 90 days prior to the SOC date will be considered. HealthCare Synergy has provided a quick reference sheet to validate a F2F completed by telehealth is compliant with this policy.
Click here to see HEALTHCARE SYNERGY – TELEHEALTH F2F ENCOUNTER QUICK REFERENCE GUIDE
The CMS MLN901705 article is available here: https://www.cms.gov/files/document/mln901705-telehealth-remote-patient-monitoring.pdf
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