Upcoming Challenges Physicians will be Facing in 2022 and 2023

September 16, 2022

This guide will discuss the changes made to the telehealth solution in 2022, and the upcoming challenges physicians will face in the coming years. We will briefly dive into the pressure congress faced due to the Covid-19 outbreak, the status of the health emergency, and the introduction of flexibility in policies.

After that, we will explore the changes introduced in telehealth policies by CMS and list down the things that will be phased out when the emergency status is lifted. Furthermore, we will also discuss what challenges physicians will face because of all these changes.

What are the Challenges Physicians will be facing in 2022 and 2023?

The PHE Status and The Future

By the end of 2021, Congress was under immense pressure regarding the future state of healthcare policies during the public health emergency (PHE) and other flexibilities introduced with the COVID-19 pandemic.

Therefore, on December 10, 2021, Congress proposed the Department of Health and Human Services (HHS) Secretary Xavier Becerra, who issued an executive order to prolong the COVID-19 PHE status by an additional 90 days.

It was essential for physicians since several flexibility and waivers under the PHE were directly connected to the pandemic and the consequences they were facing. Alongside this extension, Congress approved legislation known as the Protecting Medicare and the American Farmers from Sequester Cuts Act, mitigating cuts to Medicare physician conversion factors (CF).

According to a press release by Congresswoman Liz Cheney, with the House passage of the 'advancing telehealth beyond the Covid-19 Act of 2021 (HR 4040), the telehealth flexibilities introduced due to the pandemic will be extended through 2024.

Changes Introduced to Telehealth in 2022

Some additions include updated or new codes for extensions of temporary addition to Medicare's telehealth list and coverage up to the end of PHE (Public Health Emergency). This covers more than 100 of the services that were added to the Medicare List during the outbreak of Covid-19 pandemic.

Telehealth solution has been a key instrument for healthcare providers throughout the period of the COVID-19 epidemic. Some additions and modifications to telehealth in 2022 comprise:

  • More precise definitions of Place of Service (POS) that allow the home of the patient to be recognized as an acceptable place of service.
  • Virtual check-in and audio-only services

Since that the Centers for Medicare and Medicaid Services (CMS) telehealth waivers first were implemented on March 2020 and the increased usage of telehealth app was witnessed since the beginning of 2019, and it continues to grow.

What Will Be Phased Out from Flexibilities When PHE Expires?

According to Consolidated Appropriations Act, 2022 policies mentioned below are scheduled to expire once the PHE status is lifted:

  • More flexibility on the location where patients receive Medicare telehealth services and where the services are sourced will be reverted to the same restrictions that were in place before the COVID-19 health emergency.
  • Medicare reimbursement for telehealth solution in the mental health field will require an in-person visit within six months after the initial assessment and every 12 months after that.
  • Medicare payment for the telehealth app provided by occupational therapists, physical therapists, speech pathologists, and speech audiologists will not be permitted anymore.
  • Medicare will no longer cover audio-only physical health visits.
  • FQHCs and RHCs will no longer be eligible to receive reimbursement as distant site telehealth providers for services that are not mental health-related.

The Concerns of Physicians Going Into 2023 and Beyond

Even though the extension to telehealth services' related flexibility has been announced, physicians face many challenges. Uncertainty is growing around Congressional actions on payments through 2023.

Does the expense of running a business balance the need to maintain a profit within the provider's facility? Will remain a big question in physicians' minds.

Additionally, there will be a threat to cut Medicare. As COVID-19 continues to be the most prominent healthcare policy concern, the sheer number of hospitals struggling with staff shortages, burnout of clinical staff, and flooded facilities constantly remind them about the current PHE in effect. The ongoing extension deadline will expire in 2024 and only add more problems.

Many federal agencies, including the CMS and contractors that pay providers for their rendered care services, will not operate the same way. Therefore, discussions should be initiated immediately to avoid a federal shutdown that will occur in the future. A government shutdown was witnessed in 2018, which ran for 35 days and continued through 2019. It was by far the most prolonged shutdown of the government ever recorded in US history.


This guide walked you through the upcoming challenges physicians may face in 2022, 2023, and beyond. We also discussed the future of PHE status and what will become of the virtual visits when the flexibility provided by the government concludes.

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