In our efforts to mitigate the spread of COVID 19 many practices are closing or running with minimal staff. This could potentially result in gaps of care for patients as well as financial strain on small practices. Today we will discuss the use of telehealth and the new guidelines put in place by the Centers for Medicare & Medicaid (CMS).

Telehealth is a new revenue stream for most. The loosening of guidelines by the CMS in this time of COVID 19 it is a tool to help practices weather the resulting financial storm. There is a great deal of information available about telehealth and you will find resources linked throughout. This much information can be overwhelming so please remember we are here to help you navigate.

What has changed for Medicare?

Per the EXPANSION OF TELEHEALTH WITH 1135 WAIVER: Under this new waiver, Medicare can pay for office, hospital, and other visits furnished via telehealth across the country and including in patient’s places of residence starting March 6, 2020.  A range of providers, such as doctors, nurse practitioners, clinical psychologists, and licensed clinical social workers, will be able to offer telehealth to their patients.  Additionally, the HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.

Prior to this waiver Medicare could only pay for telehealth on a limited basis:  when the person receiving the service is in a designated rural area and when they leave their home and go to a clinic, hospital, or certain other types of medical facilities for the service.

Medicare Telehealth Visits

  • The provider must use an interactive audio and video telecommunications system that permits real-time communication between the distant site and the patient at home
  • Medicare will make payment for Medicare telehealth services furnished to patients in broader circumstances.
  • Medicare will make payment for professional services furnished to beneficiaries in all areas of the country in all settings.
  • Medicare will make payment for Medicare telehealth services furnished to beneficiaries in any healthcare facility and in their home.
  • These visits are considered the same as in-person visits and are paid at the same rate as regular, in-person visits.
  • The Medicare coinsurance and deductible would generally apply to these services. However, the HHS Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.
  • To the extent the 1135 waiver requires an established relationship, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency.

Virtual Check In

  • Virtual check-in services can only be reported when the billing practice has an established relationship with the patient.
  • This is not limited to only rural settings or certain locations.
  • Individual services need to be agreed to by the patient; however, practitioners may educate beneficiaries on the availability of the service prior to patient agreement.
  • Virtual check-ins can be conducted with a broader range of communication methods, unlike Medicare telehealth visits, which require audio and visual capabilities for real-time communication.
    • HCPCS codes for virtual check-in visits are listed below.CPCS code G2012: Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.
    • HCPCS code G2010: Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment.

E-Visits

  • These services can only be reported when the billing practice has an established relationship with the patient.
  • This is not limited to only rural settings. There are no geographic or location restrictions for these visits.
  • Patients communicate with their doctors without going to the doctor’s office by using online patient portals.
  • Individual services need to be initiated by the patient; however, practitioners may educate beneficiaries on the availability of the service prior to patient initiation.
  • The services may be billed using CPT codes 99421-99423 and HCPCS codes G2061-G206, as applicable.
  • The Medicare coinsurance and deductible would generally apply to these services.

HIPAA

  • Effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency.

List of Codes

What about other payers?

There are some differences with different payers. To assist with this information the Tennessee Medical Association and Alabama Medical Association have research some of these for you. You can find more at the links below.

Tennessee GuidanceAlabama Guidance

What technology is available?

  • Skype for Business / Microsoft Teams (as low as $5 monthly per user per month)
  • Updox (Request pricing from their website)
  • VSee (from $49 monthly)
  • Zoom for Healthcare (free for healthcare) – must use separate code for each patient
  • me (free)
  • Google G Suite Hangouts Meet (as low as $12 per user per month)
  • Cisco Webex Meetings / Webex Teams (as low as $13.50 per user per month)
  • Amazon Chime (free through June 30, 2020)
  • GoToMeeting (as low as $12 per user per month)

Patient portals and Telehealth technology platforms offered by IT vendors in which you may already have a relationship with may also be used. Check with your EHR or HIT vendor to obtain additional information regarding availability and pricing. Also consider that some medical societies offer free telemedicine platforms to members such as Tennessee Medical Association.

Blue Cross Blue Shield has a platform available in Tennessee and Alabama.

Do NOT use Facebook Live, Twitch, TikTok, and similar video services considered public-facing for telehealth services.

Patient Engagement

A good resource for how you can get your patients to use telehealth is Boosting Telehealth Adoption sponsored by BrightMD.

Here are some recommendation:

  • Use messaging from your EHR’s patient portal
  • Text patients
  • Call patients – in calling you can ask for their consent and turn it into a visit. Be sure to document the consent in the chart.
  • Advertise on social media
  • Social context affects whether or not a senior will use telehealth services. Seniors who are surrounded by friends, family members, or other care givers using telehealth will also be more likely to adopt the practice. They’ll also be much more likely to try it if their doctor recommends it so consider friend and family engagement when scheduling telehealth for seniors.

Telehealth can be especially helpful to practices in the time of COVID 19 but don’t forget you can continue to use this service to enhance your practice even after we come out on the other side.

We hope this information has been helpful. Feel free to reach out if you have questions. We can be reached by email at techassist@qsource.org or by telephone at 844-205-5540.

Resources