Our Insurance Chair, Milton Marasch, has drawn our attention to some changes to CMS place of service codes. According to at least one source, CMS looks like they will be requiring one in-person visit within 6 months of the initial tele-mental health service, and then again at least once every 12 months, with some exceptions available for the latter. APA services also reviews CMS and Medicare telehealth in 2022 here.