Even though telemedicine adoption had increased from 5% to 22% between 2015 and 2018, barriers still existed. Most providers were not clear on the reimbursement rates and there were several restrictions from Medicare/Medicaid as well. One must consult numerous restrictions around Medicaid reimbursement, private payer law and professional regulation/health & safety laws (statewide and national). A 2019 consolidated report can be found here.
There were (temporarily limited due to COVID 19 outbreak) restrictions around each modality (: Live Video, Store-and-Forward, Remote Patient Monitoring).
Traditionally, video calling was the easiest to get reimbursements for. Store and forward had numerous restrictions around what constitutes as an originating site, provider facility location (rural vs urban), whether radiology, dermatology, ophthalmology fit into the realm of “store and forward” or not etc.
However, in light of COVID 19, CMS has relaxed quite a few of those restrictions due to this public health challenge facing us all. A few salient points to note – so you can construct your telehealth strategy specifically around COVID-19.
- The qualifying rural area and facility requirements restrictions have been lifted. This enables providers throughout the USA to deliver telehealth services to their patients.
- You, the healthcare provider, are now allowed to reduce or waive all patient cost-sharing payments for telehealth visits paid by Medicare.
- In addition to Medicare, state Medicaid programs and commercial payers also have updated telehealth policies.
- HIPAA requirements around using telephone only or free video stand-alone applications have been relaxed – so you can use Skype, Whatsapp video calls.
Latest reimbursement guidelines from CMS for practices leveraging telemedicine technology
CMS updated their telehealth services guidelines recently. The document can be found here.
The crux of it is that while initial guidelines were to use place of service for billing as 02 in your EMR. Now, that has been changed to 11 – that’s the same as “face to face” or in person billing place of service. So, you do not really have to do anything extra other than to add a visit type in your EMR of “TELEVISIT”.
CMS was going to make some E/M codes effective from 2021 – this included usage of E/M codes and billing them as Medical Decision Making (MDM) or Time. Now, CMS is allowing you to choose E/M levels based on MDM or Time.
More importantly – you do NOT need to document history and / or physical exam in the medical record if you are going to use a synchronous audio-visual telehealth visit (i.e. a video call).
Typically, you needed to record a place of service as the provider’s home or “originating site” – but due to COVID-19, CMS is no longer requiring you to do so. You can just use the practice address and CMS, for this Public Health Emergency (PHE) is going to disregard all discrepancies.
For COVID-19 purposes, CMS is also covering Telephone E/Ms (CPT 99441-99443) – this is both for new and established patients.
Store and Forward (G2010) and Virtual Check-in (G2012) – now you can use it for BOTH new and established patients. Before this, you could only use it for established patients.
Updated list of covered services
The list has been updated here.
Updated list of eligible providers
While the list of providers that are eligible to deliver telehealth services has been updated, note that FQHCs and RHCs are added only during the emergency period. The current list of eligible providers include Physicians, Nurse practitioners, Physician assistants, Nurse-midwives. Clinical nurse specialists, Certified registered nurse anesthetists, Clinical psychologists (CP), Clinical social workers (CSWs), Registered dietitians or nutrition professionals.
Please note that CPs and CSWs cannot bill or get paid for Current Procedural Terminology (CPT) codes 90792, 90833, 90836, and 90838.
Where can you deliver telehealth services?
Before COVID outbreak, you needed to have a valid license in the state where you the patients resided (ie. you could not cross state borders). However, just for the time being (for COVID), this particular restriction has been removed. You can provide telehealth services in the state where an emergency is happening (e.g. NYS as of writing). However, an interesting point to note is that the state requirements will still apply.
Hopefully this allows you to create your own practice’s telehealth strategy. Let’s look at some pros and cons of telemedicine.