As you may have heard CMS has opened the door for broad based telehealth services during the COVID- 19 crisis. This will increase access to care, provide higher compensation than telephone visits, and help keep our patients and providers safe. The new rules are retroactive to March 6, 2020.
Undoubtedly you have many questions, and we have highlighted a few of the common ones coming to Culbert Healthcare Solutions.
- Are telehealth visits reimbursed as telephone visit or in-person visits?
- Medicare is reimbursing telehealth acute visits at the same rate as in-person visit. This is significantly higher than compensation for telephone codes.
- Coding and documentation should be consistent with traditional in-person visits.
- Must the provider use audio and video?
- Yes, to receive full in-person Medicare rates, both the provider and the patient must have audio/video capabilities such as a smart phone.
- If a regular telephone is used either by the patient or provider, then telephone codes are used
- Virtual check-ins, e-visit also will continue to be reimbursed
- Can telehealth visits be for medical conditions other than COVID-19?
- Yes, the goal is to provide broad care at a distance and therefore patients visits can be for other medical conditions besides COVID-19. However, it should not be used for preventative visits (such as pediatric well care) which require a physical exam.
- How does the provider document this visit?
- Providers should document in the EHR a patient encounter rather than a phone encounter. Document the interaction occurred by phone and video and document a normal soap note. Because exams are not able to be performed, it may be helpful to document the time spent on the visit, particularly for new visits.
- Must there be a preexisting relationship?
- No, CMS has waived this requirement so that new patients can be cared for and billed.
- Is there a special code or modifier to bill for Medicare?
- While no specific telehealth modifier is needed, the place of service needs to be noted as 02, rather than 11- outpatient place of service.
- A full list of allowed CPT codes is available on the CMS website.
- How do we collect patient required co-payments or deductibles?
- Providers may waive patient co-payments. While they may collect this payment, Medicare is providing flexibility to waive these in order to allow providers to initiate telehealth visits quickly without infrastructure needed to collect patient payments.
- Is this limited to certain states or locations?
- No, the declaration of a national emergency allows CMS to open telehealth broadly to all Medicare patients.
- Providers must be licensed and continue to follow state regulations regarding scope of practice.
- How do we comply with HIPPA regulations?
- HIPPA requirements of a signed waiver are suspended this at this time. However, public facing communication such as FaceTime, TikTok are not allowed.
- Are other insurers following suit?
- Yes, this is changing rapidly, and it is suggested you follow up with individual payers. They may require a modifier.
Please know that we are here to assist in any way we can. We will be as creative as necessary to support your needs as your priorities focus on the care and protection of your patients and employees.