Episode 134:
Telehealth Rules, Risks, and Red Flags for 2026

CJ Wolf: Welcome, everyone, to another episode of Compliance Conversations. We have one of our favorite guests back, Keisha Wilson. Keisha, welcome!

Keisha Wilson: Hi, CJ. Thank you for having me back again.

CJ Wolf: Absolutely, you always bring such great information, and we're going to talk more about one of your areas of expertise, telehealth, but before we jump in, if any of our listeners haven't had a chance to be introduced to you, we'd love to have you kind of tell us a little bit about yourself for those new listeners.

Keisha Wilson: Awesome. Welcome, everyone. My name is Keisha Wilson, so I am the founder of KW Advanced Consultant. I have been in healthcare now, I think, this year. Later this year makes 30 years, I know, I started young.

Keisha Wilson: I know. Study young, but I love it. I specialize in compliance and telehealth, risk adjustment. I teach medical coding, along with CJ. I speak at conferences, I write articles, a new title, since

Keisha Wilson: CJ and I last spoke as official author. I wrote a book about caregiving, and taking care of my mom. And, so I do audits, compliance, documentation. I sit as chair on a telehealth committee.

Keisha Wilson: and various boards, Outpatient mental health board, nursing board, so I do a lot when it comes to healthcare behind the scenes.

Keisha Wilson: She's a nutshell.

CJ Wolf: Yeah, exactly. And, I remember, you know, at the last conference we saw each other, you even referenced telehealth and how it was affecting your mother, and I think you told me then that you were writing a book, so I'm excited to look at that.

Keisha Wilson: Awesome, yes, thank you. May I have to be back for another conversation about that, too.

CJ Wolf: Let's do it! That's a great idea!

CJ Wolf: Awesome. Well, let's… let's jump in, Keisha, to… to telehealth.

CJ Wolf: You know, you were mentioning that there's been new laws passed recently. We're recording this, it's February 19th, and just a couple weeks ago, there was some big news. Why don't you tell us about that big news, and kind of what that legislation means, and tell us.

Keisha Wilson: Yes, I know last time we talked, we were in the government shutdown, and this time, we were very close. We had one for, like, a few days that kind of affected us, because the extension was until January 30th of 2026, and that came and passed.

Keisha Wilson: But on February 3rd, the Congress finally did pass the Consolidation Appropriation Act of 2026.

Keisha Wilson: So if you know from past presentations or conversation, we had a few consolidation appropriation acts, and they continue to be updated. So, that has allowed for the flexibilities that has

Keisha Wilson: continue to take place past the public health emergency ending on May 11, 2023, to continue on for another 2 years, so we're excited until December 31st of 2027. So there's a few, yeah, almost 2 years, they say.

CJ Wolf: So it gives us the rest of this year and all of next year, that's great.

Keisha Wilson: Hopefully.

CJ Wolf: Somebody can get something done more permanently.

Keisha Wilson: Exactly. So, yep, that's what I'm going to talk to you about, too. So, with the Consolidation Appropriation Act of 2026,

Keisha Wilson: We now continue… patients can continue to see their providers from the comfort of their home, which I use my mom as an example, especially those that have gone through chronic conditions, and we want to make sure they're safe. They can continue to stay home, they don't have to go to the office, which I think is huge right now in the landscape.

Keisha Wilson: And I'm sure some of the Congress family members also utilize telehealth, and they've been yelling at them, so I'm sure that's happening behind the scenes.

Keisha Wilson: Then we have, the audio only. They can continue to utilize that until December 31st, 2027. So that's for the non-behavioral health, because behavioral health.

Keisha Wilson: has been made permanent to continue to use audio only, so even if this expires, they are okay. We also have,

Keisha Wilson: We have quite a few. So we have that, we have the home, we have FQACs and RHCs, they can continue to be considered distant site providers and continue to provide telehealth to their patients. So that one is huge, too.

Keisha Wilson: They have a permanent, law kind of sitting on Congress, so there's, like, three. There's one for… to make the FQHCs and RACs permanent when it comes to distant sites.

Keisha Wilson: Initially, before COVID, or the public health emergency, they were only able to provide originating site.

Keisha Wilson: And so there's originating site and distance site. Originating site is where the patient goes, and they sit, and they have a telehealth visit, and the distance site is where the practitioner is in providing that service. So they were only able to do originating site, and then the public health emergency allowed them to provide distance site services, too.

Keisha Wilson: So now they can continue that, which is great.

Keisha Wilson: And so that… there's a law called,

Keisha Wilson: Permanent, I think, Telehealth from Home Act? No, no, that's not it. It's the Modernization Act. Sorry, there's quite a few. Modernization Act to make the FQHC and RHC permanent distance sites, which I think…

Keisha Wilson: It's gonna happen eventually. There's also the Connect for Health Act 2025, which is looking to remove the geographic restrictions and allow patients to continue to see their providers from home permanently.

Keisha Wilson: And then the permanent, telehealth from Home Act.

Keisha Wilson: And that one is talking about the originating site as well. So, there's a few hanging out on the desk, and we're waiting, but at least we have an extension now until 2027. Oh, and of course, the biggest one.

Keisha Wilson: Physical therapists, occupational therapists, speech-language pathologists, and audiologists can continue to see their patients until December 31st, 2027.

CJ Wolf: Nice.

Keisha Wilson: Yeah, so there's a lot.

CJ Wolf: Yeah, and you mentioned the audio only.

CJ Wolf: Is that still… Refresh my memory,

CJ Wolf: does it… does the patient or the… have to say that they cannot do the visual part of it? So it's not like we can do anything we want audio only. Is that still true?

Keisha Wilson: Yep, still true, and so you see your memory serves you, right? And so with that is…

Keisha Wilson: When it comes to audio-only services, and there's so much when it comes to telehealth, but as practitioners, we have to have the capability to provide audio and video visits for the patients.

Keisha Wilson: But the patients, they don't always have to agree or consent to the telehealth visits if they want to do audio only.

Keisha Wilson: We can let them go ahead, but we should document that in the record, so that we know. And some of them still don't have audio-video capabilities, so if not, that should be documented, so that in case there's an audit, they would understand why we did the audio-only services.

CJ Wolf: Right. And modifiers different? Is that true? Is it, like, 93 or something?

Keisha Wilson: Exactly, yep, modifier 93, and in our CPT books, we can, in the appendices in the back, we can find the modifiers for the audio only, which is the 93.

Keisha Wilson: Then we also have the 95 for the synchronous audio and video, but then you also have additional modifiers that the payers may want to see, like the FQs, the FRs.

Keisha Wilson: and other behavioral health modifiers. I always say you want to check your payer policies, because there's quite a few,

Keisha Wilson: laws that have passed in all of the states, basically. Cchp, I love their website. They always… they go through the 50 states and what have updated. And for Medicaid, there's quite a few laws when it comes to audio only.

Keisha Wilson: Services, and so you want to make sure, even though the insurance may allow, you have to check your state laws, because that may be different, and so it's still not one size should fit everyone.

CJ Wolf: Gotcha. Yeah, no, that makes a lot of sense.

CJ Wolf: And I know this, excuse me, isn't technically telehealth, maybe you consider it. You know, there's some of those newer codes that

CJ Wolf: are digital services, where you're just, like, asynchronously communicating digitally, right? Do you consider that?

Keisha Wilson: Yep, I still consider it, and there's so much… so besides the extension, we also had the final rule that came out after we spoke, so there's, like, a lot.

CJ Wolf: That's been happening and confusing for everyone, and so in there.

Keisha Wilson: CMS also addressed those beautiful, 98000 codes.

Keisha Wilson: Through 98015, so for the synchronous audio-video and synchronous audio-only calls.

Keisha Wilson: And so I always tell organizations, you want to double check to see if your provider are allowing you to bill it, because CMS had mentioned that it's a status I, that they're not accepting those codes, and that we should utilize the appropriate office or outpatient services with the appropriate place of service and modifier.

Keisha Wilson: So in that instance, they're not taking it. I reached out to quite a few Medicaid, local Medicaids, and they mentioned they are not accepting it either. We should build an appropriate E&M. So they're following what CMS does.

Keisha Wilson: There's quite a few that do take it. I'm finding a lot of the blues, like Florida Blue, Alabama Blue, they're taking it, so you always want to double check your pairs. But I think a conversation, or I mentioned it to you, is that people are confusing it with the audio only.

Keisha Wilson: the telephone calls that we had before, the 99441 and 443 that was deleted. So those were for the telephone calls, they were kind of brief, but they were still evaluation and management. If it was leading to a visit, you know, within the next 24 hours.

Keisha Wilson: or student's appointment, we couldn't bill it. But these new calls, a lot of people are not reading the description, and they're trying to crosswalk it, and it's completely different.

Keisha Wilson: If you read the descriptions and, you know, we teach

Keisha Wilson: CPT, so we read it and know it by heart, is talking about synchronous audio-only evaluation and management for a new patient or established patient.

Keisha Wilson: Medically appropriate history and or examination, and then, you know, straightforward, moderate, high decision making, but we forget to read the other part, and more than 10 minutes of medical discussion.

Keisha Wilson: So they want physicians to have that conversation with their patient. And they mentioned, if you're not having that discussion, then we should build a 98016, which is a communication

Keisha Wilson: technology service, or, right, visit, and that's for 5 to 10 minutes. So if it's less… as if it's not more than 10 minutes, you must bill that one. And I… I see a lot of people not reading it, documentation not supporting, and I'm like, oh my gosh.

CJ Wolf: Yeah.

Keisha Wilson: This is gonna be bad.

CJ Wolf: Like you said, a lot of people don't read the descriptions, and I'll have clients for… I'm just like, well, these are the requirements of the code, and they're like, how do you know that? I'm like, it's in the code description, and so here's the whole description.

Keisha Wilson: Exactly. It's like, we're not making it up, it's not in the laws, it's actually in our book, and when the OIG and the payers audit, guess what they use? They use our own guidelines.

CJ Wolf: So, it's important that we read through the descriptions and make that note.

CJ Wolf: Yeah. So, Keisha, you mentioned behavioral health kind of at the beginning, and so there's this continued delay of the in-person visit requirement. What… tell us a little bit about that, and how documentation might need to be taken care of.

Keisha Wilson: Yeah, so we had that also, I told you. A lot was happening. So, with behavioral health, there's that whole 6 months requirement that once a patient has an established telehealth visit.

Keisha Wilson: they must have come in, or Behavioral Health Service come into the office to have that first in-person visit. And so now that continues to be delayed until December 31st of 2027. So they don't have to.

Keisha Wilson: But they also mentioned that patients shouldn't be forced, and if they want to come in to see their providers in person, that should be also an option.

Keisha Wilson: But now we're in the landscape of where we have quite a few providers that are virtually only. So they don't have a physical office, and so in that case.

Keisha Wilson: what do we do? Patients do have the option, because I've spoken to quite a few people, and I think now we're in that landscape where people are actually vocal about getting therapy, and they're like, no, I want to see someone in person. I don't want to just be behind a screen.

Keisha Wilson: So I think that's important if they do have a physical office.

Keisha Wilson: They do still, even though it's not a requirement, still have them come in. Because remember during the shutdown, everyone was like, oh, what do we do? How do we get them in there? How do I, you know, rent a space now to meet that in-person requirement? So…

Keisha Wilson: I think it's important. I'm on a mental health board, and I know for them they do a lot of virtual visits, but they have office hours, too.

Keisha Wilson: Where the patients can come in and establish that rapport with the provider. So, I think that's something that people should kind of put on, their list of things that, even though this is the requirement, if you are able to, you want to do that as well.

CJ Wolf: Okay, great, great. Everyone, we're going to take a quick break, and then we're going to come back and continue with Keisha. We've got a lot more material to cover, so, hang tight, and we'll be right back.

CJ Wolf: Welcome back, everyone, from the break. Keisha, we… we're… we've been talking about telehealth, and I…

CJ Wolf: You were talking, or you mentioned to me the Medicare physician fee schedule for 2026 has this virtual direct supervision,

CJ Wolf: concept made permanent, if I understand that correctly. Tell us about that. What does it mean from a practical sense with kind of real-time audio, video, and all of those kinds of things?

Keisha Wilson: And I'm going to, kind of ask what you think, too. So, when it comes to direct supervision, we had, we've had the conversation

Keisha Wilson: Or a lot of consultants, and even compliance professionals, have talked about this, because now they changed the definition, and now virtual presence

Keisha Wilson: is allowed and made permanent for direct supervision. So before, the practitioner had to be physically present in the office. They didn't have to be in the suite, but they had to be physically present to provide that supervision, whether it's to

Keisha Wilson: NPPs, nurse practitioners, PAs, or residents for those in the teaching physician setting.

CJ Wolf: Now they're saying that it has been made permanent, and the first thing that I thought about was incident 2, and I cringed. I was like, oh my goodness. I know, I know. Because the amount of audits that we have seen, and it continues to be on the OIG list.

Keisha Wilson: For the most, you know, watch services. So, for those listening that don't know about Incident 2 services, the physician had to be in the suite, and, you know, the physician had to have seen the patient.

Keisha Wilson: create a plan for the nurse practitioners or PAs to follow. They get paid at 100% when they're seen by the NPs and PAs.

Keisha Wilson: But their presence had to… they had to be there. So they couldn't be on vacation, they couldn't be conducting surgery, they had to be readily available, and I think that's the important thing. If it was a group practice, someone else can provide supervision, but it had to be documented.

Keisha Wilson: But what we kept seeing time and time again would be they weren't there. They weren't following the Incident 2 guidelines, it wasn't an established patient, established plan, it was a new plan, it was never seen. Organizations forget, I don't know if they forget sometimes, but to credential

Keisha Wilson: The mid-level providers, so that they can bill on their own.

Keisha Wilson: Even if it's 85%, it's 85%.

CJ Wolf: Right.

Keisha Wilson: and compliantly.

Keisha Wilson: And I think that's something you've seen often too, right, CJ?

CJ Wolf: Absolutely. So, I… this is just one more reason why I…

CJ Wolf: give the advice of don't do Incident 2. Just let the nurse practitioner, the physician assistant, work at the full scope of their licensure. If it's something outside of their licensure, or they're not comfortable with it, have you send them to the doctor. This is… to me, this is just one more reason

CJ Wolf: not to do Incident 2 at all from a business standpoint, right? So I always tell them, I'm like.

CJ Wolf: And all my clients, most of the time, I just say, don't do it. And then there's always clients who are like, well, no, we have to have that extra 15%. And then I'm like, well, then are you prepared to do all of these hoops? And so I kind of paint the picture of everything you have to do. And where people, I think, get confused is that I hear the doctors say all the time.

CJ Wolf: Yeah, but why do I need to be there? That's within their scope of practice. Well, we have different overlapping regulations. What you just said, Doctor, has to do with state licensure.

Keisha Wilson: It's whether or not.

CJ Wolf: Legally, they're allowed to provide that service with you not there.

CJ Wolf: we're talking about reimbursement for one payer called Medicare. So, those are different things, and so…

CJ Wolf: they always get confused with all of that, and I don't, you know, I can see why they would get confused, but I always have to try to say, look, this is this lane, this is this lane, this is this lane.

CJ Wolf: But I know a lot of clients who are… who are going with this. They're like, this is awesome, now we can do virtual direct. And I think you're right, I think there's going to be audits,

Keisha Wilson: Yeah.

CJ Wolf: How the cycle works.

Keisha Wilson: Agree. I think everyone should put it on their audit plan for this year. If you were not listening to CJ and not doing incident, like, not providing, but you are providing the service, you want to watch, you want to look at your templates, you want to look at

Keisha Wilson: the documentation, and does it support their presence virtually? Because it should. Somewhere there, we have to know who the supervising provider is.

Keisha Wilson: How did they provide the supervision? Because they cannot conduct it audio only, it has to be audio and video, and were they readily available? So, we should see that, and you should just not take it for, you know, exactly what they're saying. There should be some kind of, oversight.

Keisha Wilson: site, you know, can we sit in on a visit somewhere to make sure it's being done? Look at the system, the templates are updated, I think people don't really pay attention to that. If Incident 2 was already an issue before, with doing it so compliantly in person, then it's not for you virtually, because

Keisha Wilson: is that provider going to be readily available? I read an article, and they mentioned, like, if the provider's going to be in surgery all day, then

Keisha Wilson: These service should not be billed incident 2, and that's why we did pop-up in person, because we knew there were some providers. If we looked at their schedule, how did you do surgery all day, but then these patients are being done, incident 2.

Keisha Wilson: So I definitely will put that on the list. And then for the teaching hospitals, in their updated, FAQ,

Keisha Wilson: CMS did mention that in teaching settings, they can continue to see, residents can provide the service, because they can provide telehealth services, but the supervision can only be done for those services that are provided via telehealth.

Keisha Wilson: So, if it's in-person requirement, they still gotta meet the in-person requirement.

Keisha Wilson: Even for the residents, they cannot do audio only. It has to be audio and video as well. And they talk about global surgeries, so if you're doing global surgeries from 10 days to 90 days, you cannot provide

Keisha Wilson: direct supervision virtually as well. They still want that physical, in person. So, we still need to make that clear. I think sometimes when there's new changes in laws.

Keisha Wilson: Selective listening?

Keisha Wilson: Or hearing? Exactly.

CJ Wolf: They're like, they're like, oh, this means I can do this for everything.

Keisha Wilson: Thanks for having me.

CJ Wolf: No, there's…

Keisha Wilson: Thanks.

CJ Wolf: There's still guardrails, and, you know, to your earlier point, and maybe this is a topic for another session at a future point, but,

CJ Wolf: if I can't convince a client

CJ Wolf: not to do Incident 2, and they're just… they're set doing it, then what I usually tell them is, well, one way to really make a good safeguard is

CJ Wolf: Have the physicians, like, have some sort of schedule.

Keisha Wilson: Yeah.

CJ Wolf: and have the physician sign. I got here at 9-12. I only took this 20-minute lunch, but I was still… right? So, just have some sort of documentation each day.

CJ Wolf: To show, because what if a physician does get called to an emergency surgery? Is there another physician in the suite to cover it? And so, I just say, okay, if you're gonna do this, here's a really good way to try to stay compliant and have documentation, but…

Keisha Wilson: Agree, 100%. And credential the mid-level providers, because as you mentioned before, they can build on their own, they're within the scope, but oftentimes you find that organizations don't, and then if that physician is not there, they're like, what do we do? Then they couldn't…

Keisha Wilson: They conduct, you know, we don't want to say fraud, but fraud, waste, and abuse is a real thing.

CJ Wolf: That's right.

Keisha Wilson: And the OIG did a telehealth, like, audit.

Keisha Wilson: during the pandemic, afterwards, like, 2020, 2021, and they talked about Incident 2 as one of the findings. That was an issue then.

Keisha Wilson: And now we're in 2026, and they've made it permanent, so I'm like, if they saw an issue then, we definitely have to put that on our, like, high on the level of our work plan to pay attention to. And the residents, the teaching position settings as well, too.

CJ Wolf: Absolutely. Is that one of the things that you were mentioning about these 1,700 providers that were kind of in this high-risk telehealth billing? So that was one. Were there any others that… that came to your mind for that on the.

Keisha Wilson: Yes, so they talked about that. They also talked about the remote patient monitoring, because of how much we utilize the service, and how much it has expanded since the public health emergency. I think there's an RPM provider every day that's popping up.

Keisha Wilson: So we need to make sure that the services are done compliantly. Cms came out with the MLN last year, and they updated about the three requirements. They need to see in documentation that's not being met. So if no one has reviewed that yet, you need to take a look.

Keisha Wilson: at the three requirements, because the OIG also mentioned that that was not being met.

Keisha Wilson: When it comes to setup and education and someone monitoring. I know we talked about nurses before, leaving bedside and going website, and this is one area where you can utilize nurses in the remote patient monitoring setting.

Keisha Wilson: Also, fraud. They talked about fraud, waste, and abuse. So, when we come to telehealth, we also have providers that are able to prescribe controlled substance to their patients, audio, video, and virtually. And the DEA, they just extended that whole,

Keisha Wilson: waiver until December 31st of 2026 when it comes to substance. So, they're able to control… continue to provide, you know, services and prescribed buprenorphine and the other controls. So.

Keisha Wilson: We need to be careful with that, because now you have… if they're using audio only, how do they know it's their patient, that they're prescribing something?

CJ Wolf: Good point.

Keisha Wilson: Exactly. We've seen many times where, there was people utilizing telehealth in someone's insurance, and the person had passed away, and now this person has a supply of controlled substance.

Keisha Wilson: So that is one. Anytime we have any federally, federal programs, Medicare, Medicaid, the VA, there's always


Keisha Wilson: We see a high use of fraud, maybe because of the population that has this insurance.

Keisha Wilson: So they talked about providers' medical necessity, our other favorite thing to talk about, the overarching criteria of why a patient's being seen, and so they also mentioned that a lot of telehealth visits were not medically necessary.

Keisha Wilson: I think… I am sure you said the same thing I did. During the public health emergency. Did… were you able to provide these services before telehealth?

Keisha Wilson: And some of the physicians were like, no. But we saw they were utilizing it in a different way, like calling the patient just to give them their blood work. That was kind of bundled.

Keisha Wilson: into the ENS, so we couldn't bill it separately. So they found that a lot of visits were not medically necessary, documentation was lacking in supporting, which should tell us that we need to update our templates. We need to provide education to our physicians so that they understand that telehealth

Keisha Wilson: It's not replacing in-person visits, so it should be conducted the same way.

CJ Wolf: Consent still… Right.

Keisha Wilson: is needed for this visit. Cost sharing and copayments apply, just like in-person visits, so that should be there. Location.

Keisha Wilson: I have to talk about location. So I had a good question asked to me yesterday, and their physician, constantly documents

Keisha Wilson: They check the patient's geographic location.

Keisha Wilson: And that's it. They're not saying where the patient is. And so, we need to know, are they home? Are they in a hotel? In a car, in a grocery store? Right? Because then place of service deter…

Keisha Wilson: determined depending on where the patient is. Besides that, is the provider licensed where the state… where the patient is located?

Keisha Wilson: So you're checking the geographic… grade, but where are they in the United States? Or are they in another country? So that needs to be documented in the chart so that the coder knows and that they can actually check

Keisha Wilson: You know, yes, they were home, place to serve as 10, or maybe 02, they were not home.

Keisha Wilson: Or use another modifier, because some of the other payers still want 11, 19, or 22. So, I think that we have quite a few

Keisha Wilson: Things to check off on our compliant list for 2026 that we need to make sure we're staying on top of?

CJ Wolf: Well, and I think the fact that, you know, telehealth is… it's broadening itself.

Keisha Wilson: Yes.

CJ Wolf: Its footprint in healthcare just means there's going to be new ways for fraud, waste, and abuse, and so we need to be thinking

CJ Wolf: all of the things that need to be audited, it should be on our work plan, like you mentioned, if you're doing a lot of it, and so…

CJ Wolf: Because you were kind of… Go ahead.

Keisha Wilson: And I was gonna say, even our providers, they are… you know, even, I mean…

Keisha Wilson: They're coming up with different things, so I know organizations are checking IP addresses also of the physicians and the patients to make sure that they are seeing who they say they're seeing, and they're not seeing double. Because people are getting very creative in 2026, I won't lie. We thought AI was an issue, but telehealth is still…

Keisha Wilson: an issue, and we need to make sure we're doing so compliantly. This is why CJ and I are having this conversation today.

CJ Wolf: Such a good point, and to that point, you know, as we're coming up towards the end of our time together, I want to ask about, kind of, this source of truth, because we have a lot of compliance people listening to encoders, but what about administrators, that have to manage all of these different service lines and types?

CJ Wolf: With all of this shifting landscape, right, legislation, new legislation, states, OIG… if you had to give, like, an administrator or somebody who oversees all of this maybe 3 websites to monitor, to help them with guidance, what…

CJ Wolf: Do you have a few that you could name?

Keisha Wilson: Yes, I was gonna… I won't say mine, but I read good articles.

CJ Wolf: I will say hers.

Keisha Wilson: Yes.

Keisha Wilson: Yes, but CCHP, the Center for Connected Healthcare Policies, they… I love their website. They have all the 50 states, they drill down to the payers, Medicare, Medicaid, they have the different laws that continue to be passed, so you want to look at your states, or if your patient is in another state.

Keisha Wilson: There are states actively passing laws, probably as we speak, for telehealth, telepsychiatry, and what one state allows, another one may not. So some of them are, allowing providers to, you know, see patients on a 90-day basis, or different stuff.

Keisha Wilson: Also the ATA, they continue to lobby when it comes to telehealth, for policies to make… be made permanent.

Keisha Wilson: And I will also say your state, if you have a high…

Keisha Wilson: Medicaid populations, your state Medicaid website.

Keisha Wilson: A lot of states already have policies set in place as permanent.

Keisha Wilson: And so, even though Medicare is still doing the dance on a lot of issues, or a lot of flexibilities, the states already have permanent laws when it comes to payment, when it comes to audio only, if they're allowing or not, or audio-video. And last one, okay, I'm gonna say 4.

Keisha Wilson: The private payers. The private payers, their websites. They have policies, they'll tell you what modifiers they want, what place of service they want.

Keisha Wilson: Some, we talked about it last time, some want you to see their own providers, so they may not allow your provider to see the patient, they want you to use their own platform and their own provider, so then you want to double-check that as well, too.

Keisha Wilson: And continue to stay abreast, because things continue to change, and the bills.

Keisha Wilson: we have links to the actual bills that have been passed, and the Federal Registrar, so… which also gives you details on what, has been made permanent and continue to be extended.

CJ Wolf: Well, and because of all those changes, that's why we keep having you back, Keisha, and I think we need to probably continue that when, you know, when there's more changes, and I know she wouldn't mention her website, but I would recommend Keisha. Look, if I had… she eats and breathes telehealth, so if I had a question, I'd be going to Keisha. So, please keep her in mind with all of these things, as well as some other things, too, but…

CJ Wolf: Definitely telehealth.

Keisha Wilson: I write a lot of articles, as you said, on those things, and I stay up. When people are sleeping, I'm eating and studying it, and then trying to give you the latest and most updated.

CJ Wolf: Exactly, and we appreciate your time today. Any last-minute thoughts or anything you want to say before… before we go? I know we've covered a lot of information.

Keisha Wilson: We have… I know we're in the landscape, too, advanced beneficiary notice. I know when we had the lapse, people were like, oh my goodness, should I start having our patients sign? You want to always make sure you have it readily available. Should there be any time you're unsure.

Keisha Wilson: or you check and you know Medicare is not going to cover service, you want to make sure that you're aware of it and the patients are filling it out. The most recent one had expired January 31st, 2026, but they said we can continue using it until the new one comes.

Keisha Wilson: So until then, you want to make sure you're paying attention to CMS. Oh, yes, CMS website and HHS. They have telehealth information as well. They are the source.

Keisha Wilson: I forgot about them, too, yes. So CMS, HHS, make sure that they are the reputable resources that you're using, too.

Keisha Wilson: And stay compliant.

CJ Wolf: Yes!

CJ Wolf: Great, great advice, and we'll end on this, you know,

CJ Wolf: you might have all these rules, it's always good to get an external set of eyes just to double-check you, because sometimes we don't know our own blind spots, because we're so deep into it, so I really think it's a good idea to have, every now and then, have somebody external, independent, come in and just check things out.

Keisha Wilson: Yes, and policies, I'm sorry, don't forget.

Keisha Wilson: Create policies and procedures. So it's not going away. If you don't have one around telehealth, you want to start creating them. I know I write them all the time for organizations.

Keisha Wilson: We come in and we assess, and we see what you're doing, and then create a policy and procedure for your organization around telehealth to start helping your providers and administrative staff stay compliant.

CJ Wolf: Yes. Keisha, you're a wealth of information. Thank you again so much.

Keisha Wilson: Thank you for having me.

CJ Wolf: Absolutely, and thank you to all our listeners. If you have a topic that you'd like to hear more about, please let us know, or if you know of an expert in a subject area like Keisha is, also you can recommend those names to us, and we can reach out to them. So, until next time, everyone, take care.

Keisha Wilson: Bye.

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