Recently, there have been several changes to help practices with billing for telemedicine . From changes in rates to privacy regulations, there are benefits in place for billers and practices during these stressful times. Various data is subject to change and therefore it is important to confer with CMS, HHS and other government agencies to ensure compliance with telemedicine billing practices. Be sure to consult with your commercial payers to check on variances with their policies.
An Overview of Telemedicine Billing Changes from the Federal Government
Relaxed regulations and special waivers have been issued at the state and federal level. Physicians can provide telemedicine services from his or her home under Medicare. The enrollment for the provider does not have to be updated for care given at the physician’s home. Payment is at the facility rate for telemedicine services while at the non-facility rate for services that would have otherwise been provided in an in-person appointment during the coronavirus pandemic. That can be a substantial difference in the amount a practice can be paid for providing services which are critical during the Public Health Emergency, and are incurring similar costs to in-office visits.
Technology Flexibility Granted for Telemedicine Sessions During COVID-19
Telemedicine can be provided by not only physicians, but also advanced care providers and other qualified healthcare professionals. Per CMS, “CMS is temporarily waiving requirements that out-of-state practitioners be licensed in the state where they are providing services when they are licensed in another state.”
Appointments can take place via a variety of video platforms, including FaceTime, Facebook Messenger, Google Hangouts, and Skype. It is important to note that the use of third-party platforms may have privacy risk and to always stay in tune with CMS updates to ensure compliance. Restricted platforms include Facebook Live, Twitch, TikTok, Zoom (See here an article on “Zoombombing”) and others.
Additionally, HIPAA privacy regulations are being temporarily waived. You are required to inform patients of the rights that have been waived during this time when using non-HIPAA compliant tools.
eMDs advises our customers to use a HIPAA-compliant, secure telehealth technology to protect your practice from security risks. The key to prolonged success is to not create any habits or use technology that could cause HIPAA compliance trouble post-COVID.
Not only are practices able to utilize telemedicine sessions for established patients, but they can accept new patients for appointments. These changes are a benefit for practices attempting to maintain business operations during social isolation and to ensure that they are taking care of patients that may not be able to get care from other clinics, or who have not visited your practice for years.
Codes, Modifiers, and Requirements for Telehealth Claims
When coding for audio-visual communication, use standard visit E&M codes. Don’t use POS 02, instead, use the place of service that would have been used if the patient had been seen face-to-face. Use modifier 95.
CMS will pay for phone calls with codes 99441-99443 and 98966-98968, online digital communication codes 99421-99432 and G2061-G2063, virtual check-ins codes G2010, G2012, and remote monitoring. Note that this is not considered telehealth service so do not use POS 02 or modifier 95 with these.
There may be other areas where modifiers are required on telehealth claims utilizing Medicare. For example, in Alaska and Hawaii, if telehealth services are provided via asynchronous methods there is a GQ modifier required.
In addition, many commercial carriers have issued COVID-19 rules. These include Humana, Blue Cross/Blue Shield, United Healthcare, Aetna, Medicaid, and Cigna. Reach out to the respective carrier for additional information.
Ultimately, government agencies are working to assist practitioners so that they can continue to provide quality care in a safe environment for their staff and for their patients. The key element is to ensure that the E/M code that best describes the nature of the care being provided is what is reported.
There is also range of additional covered telehealth services during the Public Health Emergency (PHE). In addition to typical office visits, there are a range of covered codes for psychology, psychiatry, physical therapy, counselling (e.g. tobacco and alcohol), and more. Practices should ensure they are familiar with these so that they can continue to offer the fullest range of care services for their patients who need them.
Services covered by Medicare and other carriers are still being updated daily. Please check with your Medicare, Medicaid and commercial payers regularly for updates.
To help you stay up to date on changes, please bookmark the following websites:
- Public Health Emergency – https://phe.gov
- Centers for Medicare & Medicaid Services – https://cms.gov
- Department of Health and Human Services – https://hhs.gov
- Center for Disease Control – https://cdc.gov
- Telehealth Toolkits General Practitioners – https://www.cms.gov/files/document/general-telemedicine-toolkit.pdf
- Telehealth Toolkits End-Stage Renal Disease Providers – https://www.cms.gov/files/document/esrd-provider-telehealth-telemedicine-toolkit.pdf
- AMA Toolkit – https://www.ama-assn.org/system/files/2020-03/covid-19-coding-advice.pdf