Medicare Telehealth Reimbursement Expanding in response to Coronavirus (COVID-19)

 

Note: Things are rapidly changing, and we’re gathering information as quickly as possible to keep you updated. We’re starting with this article about Medicare guidance so that you can help protect your older patients and provide options.  If you have any questions regarding these resources, please don’t hesitate to contact us with any questions at info@keystonemm.com.

Specialists and private practices across the nation are facing new challenges in providing ongoing care to their patients, particularly Medicare beneficiaries and other vulnerable patient populations. Many providers are exploring telehealth as a critical care option for their practices. Here are the evolving legislative changes that may open up additional telehealth options for your practice and your patients.  

Last week, Congress passed the Coronavirus Preparedness and Response Supplemental Appropriations Act (link here). This legislation paved the way for expanded telehealth coverage, by waiving or modifying previous restrictions on telehealth for Medicare beneficiaries and providers. On March 13th, President Trump declared a National Emergency under the Stafford Act. This declaration mobilized emergency measures and cleared the way for further expansion of telehealth coverage and reimbursement. Here are the key changes that may impact your practice and patients:

The originating site requirement has been waived.

Previously, Medicare restricted telehealth to visits between a patient and provider when the patient connected from an eligible, originating site. Coverage requirements stated that the originating site needed to be:

  • A county outside a Metropolitan Statistical Area (MSA) or

  • A Rural Health Professional Shortage Area (HPSA)

  • AND be in a specific eligible site, which included provider offices, hospitals, rural health clinics, and more. 

Recent legislation gave the authority to waive the originating site requirement, during an emergency period. 

Telehealth services can be provided by phone, if the phone allows for audio-video interaction between the provider and beneficiary.  

Providers still need to follow state laws and HIPAA (Health Insurance Portability and Accountability Act) guidelines that govern the use of technology for ePHI. Your local Medical Fiscal Intermediary should provide guidance on acceptable equipment. Noridian, the local Medicare Part B administrator for Jurisdiction F (Alaska, Arizona, Idaho, Montana, North Dakota, Oregon, South Dakota, Utah, Washington and Wyoming), states that acceptable equipment for telehealth services includes ‘professional Skype-like products’ and advises that ‘HIPAA guidelines require that any software transmitting protected personal health information meet a 128-bit level of encryption, at a minimum, and need auditing, archival and backup capabilities’. 

Important Resource

MEDICARE TELEMEDICINE HEALTH CARE PROVIDER FACT SHEET

Key Points to Consider

  • Unless future legislation states otherwise, these expanded telehealth services are limited to qualified Medicare providers, who have furnished Medicare services to the patient within the three years prior to the telehealth service. This does include services that were provided by another qualified provider under the same tax identification number. 

  • The patient must initiate the telehealth service. You are allowed to notify patients that telehealth services are available. 

  • The patient must give consent to be treated via telehealth, and the consent should be documented within the patient’s medical record PRIOR to the initiation of the service.  

  • It’s important to understand the difference between telehealth and telemedicine. Although the terms are often used interchangeably, Medicare designates these differently, and applies different coding and technology requirements.  

Billing/Coding Tips and Resources

  • To bill telehealth services, providers will use standard evaluation and management codes (such as established patient office visit 99213) and designate the place of service on the claim as POS 02, to signify synchronous telehealth.

  • Box 32 should include where the practitioner typically practices. 

  • Documentation for telehealth visits should follow documentation and coding requirements for traditional in-office visits. 

  • Asynchronous (store and forward) visits are currently only covered for distant sites located in Alaska or Hawaii. These should be billed with GQ modifier.

  • Providers should familiarize themselves with who qualifies as an eligible provider under CMS. Eligible providers include:

    • Physicians

    • Nurse Practitioners

    • Physician Assistants

    • Clinical Psychologists

Important Resource

Medicare Telehealth Frequently Asked Questions (FAQs) Update May 15, 2020

CMS Frequently Asked Questions Video

Additional Resources:

We recommend that you check with your local Medicare contractor for specific guidance and billing guidelines for telehealth services in your area. Coverage for commercial payers and Medicaid programs will differ by state, and may be subject to state licensure requirements and telehealth laws. We will be posting blog updates as additional guidance from CMS and Medicaid programs becomes available.

For more information from CMS regarding telehealth requirements, billing and coding, check out their educational provider video and handout. Note: These resources predate the emergency legislation, and some eligibility requirements have changed. This is an evolving situation, and we will be updating our blog as CMS issues guidance around the changes. 

Medical Learning Network Booklet
TelehealthServices

Billing for Telehealth Encounters
AN INTRODUCTORY GUIDE ON FEE-FOR-SERVICE

 
 
Jonathan McClung