Not sure I agree,; based on CMS description, its in the context of the PHE and to mitigate exposure risk when appropriate. That isn't the case for every patient and there are times where it's appropriate and isn't. Having a blanket statement that all OTVs can be routinely done remotely doesn't seem right, but perhaps open to interpretation based on others on this forum.We are still in a PHE. And lots of patients aren't vaxed. This is not my practice but I can't find fault with it
Many private payers in my area don't pay for 77427 remotely now either (like when addending a -GT modifier or similar to it). CY 2021 telehealth services in CMS-1734-F places 77427 in Category 3, which according to them is "Services we are not adding to the Medicare telehealth list either permanently or temporarily." See the table below.
Anecdotally - we used 77427 remotely when COVID spiked a couple of times in our area and based on patient risk (vaccination status, comorbidities, COVID burden in our clinic, when we had a physician out sick with covid and otherwise couldn't deliver the OTV service, etc) but not routinely.
(https://www.cms.gov/files/document/12120-pfs-final-rule.pdf)