During the government shutdown, Medicare has reverted to pre-COVID telehealth rules, which means certain psychological and neuropsychological testing services — including CPT 96136, 96138, and 96132 — may no longer be covered when delivered via telehealth.
Key Changes
- Telehealth limits reinstated: Coverage applies only to patients in a qualifying rural area who are at an approved originating site (such as a clinic or hospital).
- Home-based telehealth typically no longer qualifies for Medicare coverage.
- Practitioner limits: Only physicians, NPs, and PAs are eligible telehealth billers.
- Documentation: Claims must include the correct POS (02) and modifier (95), and document location, consent, and technology used.
Provider Action Steps
- Review and verify telehealth eligibility for Medicare testing patients.
- Convert nonqualifying telehealth visits to in-person when needed.
- Avoid billing 96136, 96138, or 96132 via telehealth until CMS confirms ongoing coverage.
- Keep thorough documentation to minimize post-shutdown audit risk.
Bottom Line
As Medicare returns to pre-pandemic telehealth standards, CPT 96136, 96138, and 96132 may no longer qualify for telehealth reimbursement unless the patient is in a rural, approved originating site with an eligible practitioner.
Stay proactive — verify coverage before billing to avoid denials and compliance issues.
Reference: MLN901705 – Telehealth Services
