The disruption the COVID-19 pandemic has created within the healthcare delivery system and the high demand for access to care have led to rapid and extensive expansion of coverage for telehealth services. Not only do providers now have greater flexibility to safely treat patients using telehealth modalities, but reimbursement for those services has also improved. Medicare has recently announced that it will begin payment for office, hospital and other visits associated with telehealth. Patients can also now receive telehealth services in all areas of the country and in all settings, including their home. Medicare will also begin to pay physicians for evaluation and management (E/M) telehealth services at the same rate as in-person visits for all diagnoses, not just those services related to COVID-19.
With the changes in venue for a visit from in-person to virtual, it is key for providers to understand the appropriate documentation requirements for these services. Healthcare organizations should begin to educate clinicians so that they are equipped with not only knowledge of the required technology utilized to conduct the visit, but also the necessary scripting required to conduct an effective virtual care session. Providers should still properly document these visits within the electronic health record as if it were an in-person visit, including key documentation concepts like medical decision-making. This will maintain all clinical information within the patient’s medical record, including orders for procedures, medications and follow-up.
Additionally, ensuring proper documentation will provide the necessary requirements to support billing for telehealth visits. Providers should capture advanced consent from patients for telehealth interactions. This should also be documented within the patient’s record. As more and more clinicians become familiar with telehealth, healthcare systems are highly likely to continue to see telehealth as a viable option for providing care.
Another aspect of telehealth that is top of mind for healthcare organizations is the subject of appropriate reimbursement. This is especially important as elective surgeries are postponed until further notice. The Centers for Medicare & Medicaid Services (CMS) has substantially expanded the number of common procedural terminology (CPT) codes for which Medicare will reimburse a provider organization, including telephone-only CPT codes.
The provision regarding the permissibility of providing telehealth services over “telephone” or audio calls in the Interim Rule is as follows: “… this means that E/M services can be provided via telephone audio calls, but the device used must be a telecommunications device that can, at minimum, transmit two-way audio/visual interactive communication (i.e., a smartphone).” In other words, CMS will reimburse telehealth audio-only calls, but at a minimum, the device used should be a smartphone. For facility billing pertaining to Medicare and most commercial payers, coding and billing departments should append modifier 95 to appropriate telehealth CPT codes to notate that the service is being provided virtually.
During the public health emergency, those billing professional fees should report the place of service code as if the service was provided in person. Using Place of Service Code 02 on claims is valid, but CMS is not necessarily advising providers to do so; instead, it is allowing them to use discretion when selecting a place of service code. Specifically, CMS states that providers should use “the code that reflects the kind of care that the provider is furnishing” and best reflects the payment rate that would have been assigned ordinarily. As an example, CMS confirmed that it would be appropriate for a typical Medicare Part B fee-for-service provider to bill a clinic-based service using an outpatient code, and it would also be permissible for a provider to bill a home-based service using a home-based code.
Given that the types of covered services and the coding/billing requirements change frequently and vary significantly by payor, plan and state (e.g., Medicaid), healthcare organizations should develop and maintain a matrix of covered CPT codes, modifier/POS, patient-provider relationship and co-pay collection requirements. This should be a collaborative effort among coding, chargemaster and denials management to maintain and continuously reassess the document. Establishing these solid foundations for telehealth is crucial not only during this crisis but also for the longer-term future, as telehealth will most certainly continue to be a popular choice for patients.
For more on telehealth and managing during the COVID-19 crisis, listen to our recent webinar.
